februry 2010 analysis of e-cycle programs in washington ......pioneering product stewardship...

Februry 2010 Analysis of E-Cycle Programs in Washington and Oregon | page i

Cover

Cover

Developed as a Project of the Northwest Product Stewardship Council

Funded by the King CountySolid Waste Division, Washington

March 2010

Preliminary Analysis ofE-Cycle Programs in

Washington and Oregon

page ii | Analysis of E-Cycle Programs in Washington and Oregon February 2010

Funded by the King CountySolid Waste Division, Washington

NWPSC Electronics Subcommittee Members

Lisa Sepanski, King County Solid Waste Division, Project Manager

Sego Jackson, Snohomish County Solid Waste Division

Kathy Kiwala, Oregon Department of Environmental Quality

Scott Klag, Metro Solid Waste and Recycling Department

Miles Kuntz, Washington Department of Ecology

Suellen Mele, Washington Citizens for Resource Conservation

Margaret Shield, Local Hazardous Waste Management Program in King County

Prepared by

• Alcorn Consulting• Eco Stewardship Strategies• PRR• Full Circle Environmental

Developed as a Project of the Northwest Product Stewardship Council

March 2010

Preliminary Analysis ofE-Cycle Programs in

Washington and Oregon

Februry 2010 Analysis of E-Cycle Programs in Washington and Oregon | page iii

Executive SummaryThe Northwest Product Stewardship Council (NWPSC) commissioned this report to assess the first ten months of two pioneering product stewardship programs which recover used electronic products in Washington and Oregon. The programs are called E-Cycle Washington and Oregon E-Cycles.

The specific goals of this report are:

• To provide an overview of the E-Cycle programs’ requirements and provide a descriptive summary of how the programs have been implemented from January to October, 2009 in Washington and Oregon.

• To identify and analyze the statutory and policy differences between the Oregon and Washington programs that have resulted in unique program outcomes.

• To determine lessons learned from the respective experiences in Washington and Oregon drawing from analysis of quantified results (e.g., the number of tons collected and recycled, number of collection locations) and observations of key stakeholders involved in program implementation.

Thirty eight stakeholders involved in the implementation of the E-Cycle Washington and Oregon E-Cycle program were interviewed in November and early December, 2009. These stakeholders were asked to comment and provide insight on a range of issues relevant to the development and first ten months of implementation of the E-Cycle programs including program operations, environmental impacts, policy issues and economics. Interviewees included plan/program managers implementing the E-Cycle programs, electronics manufacturers, private solid waste companies, collectors, transporters, state and local government, processors/recyclers, environmental non-governmental organizations, and refurbishment/reuse organizations. Because of the small number of stakeholders interviewed in each category, these findings are not statistically significant. However, they do provide a useful temperature check after the first year of program operation and provide information to consider as the programs evolve.

E-Cycle Program Description Many similarities exist between the legislation that provides the backdrop for the E-Cycle programs in Washington and Oregon. The Oregon law which was passed in 2007, just one year after Washington’s law, included many of the same components as the Washington law in an attempt to make the program easier for the manufacturers and service providers to implement.

The laws in both states require manufacturers of TVs, computers and monitors to pay for and implement recycling programs for TVs, computers and monitors from specific consumers. All manufacturers must register with the state environmental agency and participate in a plan (in Oregon, once the plan is approved it is called a “program.” In Washington, it continues to be called a “plan”).

In both states, officials assign each manufacturer a percentage of the amount of collected electronics that have been returned for recycling called a “return share.” Each manufacturer is responsible for this portion of the program. The laws in both states require mandatory sampling of returned electronics by brand name in order to provide the basis for the manufacturer-specific return shares. The return share represents the obligation of each manufacturer in terms of the amount that must be collected by the plans.

The manufacturers have the option to participate in a “default” plan. Alternatively, a manufacturer or group of manufacturers can petition the state to implement their own plan. Their plan must be submitted to their state environmental agencies and must include a description of how their collection, transportation and recycling programs will function. Once approved, the plans can be implemented.

page iv | Analysis of E-Cycle Programs in Washington and Oregon February 2010

In 2009, the initial program year, Oregon DEQ approved three recycling plans in addition to the “default” State Contractor Program (SCP) which was run by a contractor. Washington had a single approved recycling plan in 2009, the “default” program operated by the Washington Materials Management and Financing Authority (WMMFA). The programs in Oregon and Washington have many similarities and differences which are summarized below.

Similarities between Oregon and Washington Programs:• Manufacturers role: The electronics manufacturers are required to finance and implement the recycling program

including the collection, transportation, recycling/processing, system operations and some promotion.

• Scope of products: The scope of products covered by both states include computers, monitors and televisions. Peripherals such as mice and keyboards are not included.

• Government role: The state environmental protection agencies provide program oversight, enforcement, ensure environmentally sound recycling and help advertise the program. Local governments promote the program within their jurisdictions.

• Collection services: Collection services are required to be publically accessible in all cities with populations of 10,000 or more and in all counties.

• Manufacturer registration: Manufacturers are required to register with their respective state’s environmental agency and pay an annual fee to support program administration, oversight and enforcement by these agencies.

• Default programs: “Default” programs that electronics manufacturers can participate in to comply with the requirements of the law have been established in both states. Both state laws allow the manufacturers or groups of manufacturers to run their own programs independently of the default programs.

• Environmental management standards: Both states have established environmental management standards for collectors, transporters and processors/recyclers.

Differences between the Oregon and Washington Programs:• Entities covered by the program: Washington provides access to the recycling system to “consumers” defined as

any household, charity, school district, small business (defined as less than 50 employees), or small government. Oregon covers any household, small business (defined as 10 or fewer employees), 501(c)3 non-profit charities employing 10 or fewer employees, or any person giving seven or fewer covered electronic devices to a collector at any one time.

• Default programs: Washington’s default program is a state-created organization called the Washington Materials Management and Financing Authority (WMMFA) that has a board of directors made up of electronics manufacturers who oversee the program. Oregon’s default program, the State Contractor Program (SCP), is run by a contractor selected by the Oregon Department of Environmental Quality (DEQ) and has no direct manufacturer oversight.

• Service provider registration: In Washington all collectors, recyclers and transporters must register with the state. No such service provider registration requirement exists in Oregon.

• Manufacturer Plan requirements: In Oregon all plans are free to choose any service provider to comply with various requirements (e.g., hiring collectors in every city of 10,000 or more). In Washington the default WMMFA must work with any collector registered with the state and must “fairly compensate” those service providers. In both states, service providers must meet environmental management standards which are established in each state.

• Performance targets: Oregon DEQ set a minimum 3.3 lbs. per capita collection target for the Oregon E-Cycle program for covered electronics. No such minimum target was established in Washington. Both states also have a convenience requirement to provide collection services in each county and at least one ongoing collection site in all cities with a population of 10,000 or more to ensure that the service is accessible and convenient.

• Return share obligations: In Oregon programs must collect and recycle, at a minimum, their share of electronics articulated by DEQ in pounds of covered electronics (not a percentage). In Oregon programs must operate throughout the

Februry 2010 Analysis of E-Cycle Programs in Washington and Oregon | page v

year (even if they have met their minimum), and would be penalized if they did not achieve their target except for the State Contractor Program (SCP). In Washington, when or if there are independent plans, the plans would compete with each other to collect and recycle their percentage return share of electronics established by the state. Plans that fail to meet their share must pay plans that have collected more than their share a set amount per pound for the material that was collected by the other plans.

• Administrative rules: Oregon has implemented the first year of its program without rules, relying on the statute and several guidance documents. Washington enacted regulations in 2007.

• Disposal ban on computers, monitors, TVs: Oregon has a disposal ban prohibiting computers, monitors and TVs from disposal in the trash which became effective on January 1, 2010 (one year after the collection programs began operating). Washington state has no ban although several counties have banned these materials from their local garbage systems.

• Apportionment of default program costs: In Washington the WMMFA Board establishes the financing policy for all the WMMFA members. In Oregon the law specifies that TV manufacturers participating in the SCP pay according to their respective market share of all TV manufacturers in the SCP, while manufacturers of desktops, laptops and monitors in the SCP pay according to their return share. Independent plan apportionment of costs is determined by participants in the independent plans.

Summary of Program FindingsThe following findings are distilled from an analysis of quantified results (e.g., the number of tons of electronic products that were collected and recycled, number of collection locations) and observations of key stakeholders involved in program implementation.

Program Operations• Operational startup was smooth and collection amounts exceeded expectations. Programs in both states are

showing very high collection rates of covered electronics with Washington collecting 38.5 million pounds and Oregon collecting approximately 19 million pounds in 2009. Both states collected over 5 lbs per capita in their first year of operation.

• Collection service is available in all cities with a population of 10,000 or more and in each county. The convenience requirement in both states appears to be effective for ensuring that collection service is available in each county and all cities with a population of 10,000 or more. There are now 240 collection sites in Washington and 230 in Oregon – a significant increase from pre-program collection activities.

• Processing capacity has increased in the Northwest. Two of the eight WMMFA processors/recyclers were established in Washington because of the new law and one major processor/recycler established a facility in Portland, Oregon because of the E-Cycle programs.

• The programmatic model of establishing a “default” stewardship program with an option for multiple manufacturer-run programs has proven to be viable to date. In Oregon this model has resulted in three approved manufacturer-run programs in addition to the “default” state-managed contractor program. In Washington, all manufacturers opted in 2009 to participate in the “default” Standard Plan run by the manufacturer-managed WMMFA.

• Interviewees supported flexibility with regard to the collection of electronics. In both states there is IMS Recycling located a new facility in Vancouver, Wa in part

due to the E-Cycle programs in Washington and Oregon

page vi | Analysis of E-Cycle Programs in Washington and Oregon February 2010

widespread use of the existing infrastructure for collecting electronics. In both Oregon and Washington, some programs developed collection systems using existing networks of charitable organizations. Some Oregon programs made arrangements with transfer stations operated by public entities and private solid waste companies to collect electronics. Most programs used a combination of private businesses, charitable organizations, and public sector locations.

• Some organizations that specialize in reuse and refurbishment of electronic equipment have thrived under the new system while others have struggled. Those who have thrived have either continued to refurbish old electronics and have become qualified to provide service as a recycler/processor under the new system, or have discontinued their refurbishment activities. A more detailed analysis of the dynamics of reuse in electronics recycling programs beyond the Pacific Northwest would be helpful to confirm this conclusion as the analysis in this study is based on limited experiential data.

• Charitable thrift organizations are satisfied with the program. By serving as collectors for the E-Cycle programs, charitable thrift organizations are now getting paid to collect the equipment rather than often having to pay out of pocket to recycle donated broken equipment. In Washington there are 141 locations operated by charities, including 96 Goodwill sites and these locations have become some of the most popular drop off sites. In Oregon charities have maintained their prominence as a dominant collector of used electronics in that state with more than 100 locations.

• Program education and promotion efforts need to be coordinated by a single entity. Program promotion and outreach is typically a cooperative effort across approved plans/programs, the state (using administrative fee proceeds) and local governments. When only a single plan/program exists it is easier to place more responsibility on that entity (e.g., the WMMFA) for overall system promotion and outreach. However, when multiple programs are approved as in Oregon, several stakeholders opined that in the interest of developing a coherent message to the public and to ensure a level playing field the regulatory agency should take the lead on system promotion and education.

Economics• The E-Cycle programs generated new jobs in Washington and Oregon. According to interviews of processors/

recyclers, approximately 140 net new jobs were created across Washington and Oregon for program start-up: 79 in Washington and 61 in Oregon. Approximately 360 ongoing jobs at these facilities are reported attributable to the Washington and/or Oregon E-Cycle programs.

• Most collectors interviewed felt that the level of financial compensation for providing collection service is adequate. Most collectors interviewed that were participating in the program were satisfied with the compensation. The two entities interviewed that were not participating in the system said that the compensation was too low. Those participating in the program operate facilities that were well suited to providing collection services including adequate storage space and easy public access. Those that weren’t participating stated they had logistical challenges. This may have contributed to higher operating costs and the perception that the compensation was too low to cover their costs.

• The state-wide systems created program efficiencies and drove pricing for services lower. The consolidation of electronics recycling activities into state-wide systems has created program efficiencies relative to the cost of collection, transportation and recycling before January 1, 2009. For example the WMMFA cited operating costs in 2009 as $0.24/lb and the Oregon SCP cited a similar rate – a cost well below prices charged to scattered local governments and private programs before E-Cycle implementation, according to several local government officials. Some of this pricing reduction is likely due to increased program efficiencies (e.g., a consolidated administrative structure) and some is likely due to the stronger pricing power that comes with larger, consolidated purchases of recycling and related services.

• Cooperation and joint activities across states has created efficiencies. Officials and stakeholders in Washington and Oregon developed a joint E-Cycle name, logo and educational materials which saved money and provided a consistent message to consumers across states. This example of cross-state cooperation was possible because the programs are so similar operationally. Additional opportunities to develop cross-state efficiencies and avoid confusion in border communities may also exist.

• The long-term ability of service providers to thrive under a producer responsibility system is untested. Overall the short-term results are mixed: while some processors and other stakeholders expressed concern that the new system has resulted in a negative financial impact on processors, other processors with newly established facilities in the region expressed satisfaction with current arrangements.

Februry 2010 Analysis of E-Cycle Programs in Washington and Oregon | page vii

• Managers of the “default” programs in both states expressed concern about the long-term sustainability of both programs under certain conditions. Concerns included impacts upon their programs if the financing policy that uses a combination of market share and return share to allocate costs among manufacturers could inadvertently cause manufacturers to leave the “default” program, potentially putting its viability at risk. In both states, certain manufacturers with higher market shares than return shares would pay more than their return shares under the “default program”, and if they leave the default programs the costs to all manufacturers remaining in the default program would increase.

Environmental Impacts• Most covered electronics are now being managed in audited recycling channels rather than disposed in

landfills or managed in unaudited recycling channels. The consensus among most interviewed stakeholders was that the system provided greater accountability for the final destination of the covered electronics due to annual audits of direct recyclers/processors, recordkeeping requirements and review by state regulators. Prior to the E-Cycle programs, there was no mechanism to determine if computers, monitors and TVs were being handled in a manner protective of the environment and human health. An environmental NGO said the audit process should go further – for example, leakage from collectors who are not audited is a concern.

• Collection and recycling of covered electronics has increased. Washington collected 38.5 million pounds of electronics for recycling and Oregon is collected approximately 19 million pounds in 2009 for a total of more than 5 pounds per capita. As a comparison in 2008, the Department of Ecology reported that 34.5 million pounds of electronics were recycled statewide - this figure includes all types of electronics (including printers, scanners, fax machines and other products not accepted by E-Cycle programs) from all sectors including large businesses.

• Approximately 5 million pounds of lead have been recycled as a result of the Washington and Oregon E-Cycles Program.

• More than 25,000 units have been reused in Oregon during the initial nine months of the Oregon E-Cycles program. The Washington program allows collectors to resell or donate equipment for reuse, but does not track reuse activities.

Policy• Most stakeholders

expressed support for the producer responsibility concept. This includes support from several manufacturers although some manufacturers and plan/program managers took exception to specific elements in the approach used in Washington and Oregon, specifically the prescriptive collection requirements. Some service providers questioned their own long-term sustainability in a system where global manufacturers finance and drive the system towards lower costs. Local governments in particular are very supportive of the E-Cycle programs.

• Allowing collectors to work for multiple plans is very popular among manufacturers. While manufacturers like this arrangement, questions about certain “shared collector” practices were raised by some government officials and plan/program managers. Manufacturers noted that the ability to share collectors was critical in meeting collection service requirements, particularly in more rural areas where the number of potential staffed collection sites is limited. Critics of

E-Cycle programs track the fate of all products so fewer computers, monitors, and TVs are dumped or sent to unaudited recyclers.

page viii | Analysis of E-Cycle Programs in Washington and Oregon February 2010

collector sharing arrangements point to concerns about data reporting integrity, a reduced ability of programs to spot leakage (e.g., a change in product mix could be due to the collector sending some collected electronics to another plan/program), and the public benefit of more collection opportunities if collector sharing were restricted.

• Projecting a minimum number of pounds that each program must collect presents challenges and can create a disincentive to collect more than the target. Oregon established a minimum number of pounds of covered electronics that each program must collect that year (3.3 lbs./capita) and underperforming programs must pay a penalty for not collecting their minimum pounds. Actual collections for 2009 were recorded at 5.13 lbs./capita. While DEQ required all programs to continue to provide collection service through all of 2009, it appears that some programs may have undertaken efforts to reduce flows of covered electronics from their collectors, including encouraging shared collectors to send electronics to other programs. The Washington program establishes plan-specific percentages where under-performing plans pay over-performing plans. The Washington approach has yet to be tested as there was only one plan operating in Washington in 2009.

• Few stakeholders had comments about the overall financing mechanism in the respective programs. However, specific issues were raised, including support for the financing structure where the Washington Department of Ecology establishes individual manufacturer return share obligations but the WMMFA board is allowed to set financing policy for all WMMFA members.

• Stakeholders voiced little concern with manufacturer registration requirements. Registration with a state agency is a common requirement across many states with producer responsibility programs. In Washington and Oregon an administrative fee is levied in conjunction with manufacturer registration and is based on a sliding scale based on the market share of all manufacturers of covered electronics. The only complaint raised about the manufacturer registration process had to do with the relatively high fees levied on manufacturers, particularly in Washington.

• Stakeholders had insightful comments about expanding the programs to include other products – and any new producer responsibility programs. One manufacturer said any new electronic products should be added to the existing system, while another manufacturer serving on the WMMFA board noted that it was challenging to work on a system with two disparate product groups (TVs and computers) and if you added new products to the Authority [WMMFA] it could quickly become unwieldy.

• A clear legal status and startup funding are both critical in any new program. As for the creation of any other similar system with WMMFA-type operational responsibilities, another manufacturer active at the creation of the program strongly recommended that the legal issues need to be resolved before the program is created. Specifically the legal status of entity needs to be determined (is it a public or private entity or a combination) and the legal requirements that pertain to that entity need to be identified. Also there should be funding for start up operations included in any new such program for other products.

Approximately 140 net new recycling jobs were created across Washington and Oregon for program start-up.

Februry 2010 Analysis of E-Cycle Programs in Washington and Oregon | page 1

Cover .........................................................................................................................................................................................i

Executive Summary ............................................................................................................................................................... iii

Table of Contents ....................................................................................................................................................................1

1.0 Purpose and Scope ...........................................................................................................................................................2

2.0 Washington and Oregon E-Cycling Programs ..............................................................................................................22.1 Common Elements Within Oregon and Washington .......................................................................................................42.2 Notable Differences Between Oregon and Washington .................................................................................................52.3 Description of Entities Responsible for Implementing Recycling Plans ..........................................................................62.4 Processing (Recycling) Infrastructure .............................................................................................................................72.5 Collection Infrastructure ..................................................................................................................................................8

3.0 Summary of Program Data...............................................................................................................................................9

4.0 Summary of Stakeholder Interviews ............................................................................................................................ 124.1 Feedback on Program Operations ............................................................................................................................... 12

4.1.1 Perceived Satisfaction of the Program Amongst Key Stakeholders ..................................................................... 134.1.2 Other Overall Operational Issues ......................................................................................................................... 134.1.3 Specific Operations Issue: Management of Materials from Covered Entities vs. Non-Covered Entities ............. 144.1.4 Specific Operations Issue: Management of Covered Electronics vs. Non-Covered Electronics ......................... 154.1.5 Specific Operations Issue: Reuse and Refurbishment ......................................................................................... 154.1.6 Collector Participation and Compensation ...........................................................................................................164.1.7 Economic Impacts on Processors/Recyclers .......................................................................................................194.1.8 System Promotion and Advertising ......................................................................................................................20

4.2 Environmental Impacts ..................................................................................................................................................214.2.1 Changes in Covered Electronics Flows ............................................................................................................... 214.2.2 Design for Environmental Improvements .............................................................................................................214.2.3 Backhauling Benefits ...........................................................................................................................................22

4.3 Policy ............................................................................................................................................................................224.3.1 Overall Producer Responsibility Approach ...........................................................................................................224.3.2 Connection Between Producer Responsibility and Curbside Collection .............................................................234.3.3 Impact of Allocation of Responsibility Across Producers .....................................................................................244.3.4 Cost vs. Benefit of a Statistically Viable Sampling Program ...............................................................................244.3.5 Single Plan vs. Multiple Plans ..............................................................................................................................244.3.6 Performance Targets .........................................................................................................................................254.3.7 Manufacturer Registration Process ......................................................................................................................25

4.4 Economics .....................................................................................................................................................................26

5.0 Summary of Findings ....................................................................................................................................................275.1 Program Operations ......................................................................................................................................................275.2 Economics .....................................................................................................................................................................285.3 Environmental Impacts ..................................................................................................................................................295.4 Policy .............................................................................................................................................................................29

Appendix 1 - Active Oregon Collection Locations ............................................................................................................31

Approximately 230 total .......................................................................................................................................................31

Appendix 2 - Active Washington Collection Locations ...................................................................................................38

Appendix 3 – Questions Asked of Stakeholders ...............................................................................................................46

Appendix 4 – Distribution of Stakeholders Interviewed ..................................................................................................49

Table of Contents

| Analysis of E-Cycle Programs in Washington and Oregon February 2010

1.0 Purpose and ScopeThe Northwest Product Stewardship Council (NWPSC) commissioned this report to assess the first ten months of two pioneering product stewardship programs to recover used electronics in Washington and Oregon. Specific goals of this report are:

• To provide an overview of the E-Cycle programs’ requirements and provide a descriptive summary of how the programs have been implemented from January to October, 2009 in Washington and Oregon.

• To identify and analyze the statutory and policy differences between the Oregon and Washington programs that have resulted in unique program outcomes.

• To determine lessons learned from the respective experiences in Washington and Oregon drawing from analysis of quantified results (e.g., the number of tons collected and recycled, number of collection locations) and observations of key stakeholders involved in program implementation.

2.0 Washington and Oregon E-Cycling ProgramsIn 2006 the State of Washington enacted landmark legislation to establish an extensive, statewide system for the collection of used televisions and computers for recycling. In 2007 Oregon enacted similar legislation.

Figure 1 presents a high level overview of the relationship between state regulators, recycling plans/programs, recyclers, collectors and consumers.

In general, the legislation requires manufacturers of TVs, computers and monitors to pay for and implement recycling programs for TVs, computers and monitors from specific consumers. All manufacturers must register with the state environmental agency and participate in a plan – also called a “program” in Oregon. They must submit a plan to their state environmental agencies which describes how their collection, transportation and recycling programs will function. Once approved, the plans can be implemented. If manufacturers don’t participate in a plan, they are not allowed to sell product into the state.

The manufacturers can participate in a “default” plan established by the state or a manufacturer or group of manufacturers can petition the state to implement their own plans. In both states, officials assign each manufacturer a percentage of the amount of collected electronics that have been returned for recycling called a “return share.” Each manufacturer is responsible for this portion of the program. The laws in both states require mandatory sampling of returned electronics by brand name in order to provide the basis for the manufacturer-specific return shares. The return share represents the obligation of each manufacturer in terms of the amount that must be collected by the plans.

In 2009, Washington had only one plan, the “default” plan, so that plan is responsible for 100% of the return share. If in the future, manufacturers successfully petition the state to operate their own “independent” plans in Washington, they would be responsible for the return shares of all the manufacturers who are part of that plan. In Oregon, there are three programs run by the manufacturer called “manufacturer programs” in addition to the default program. Each manufacturer plan or program decides how they will apportion the costs of their program to the manufacturers that are participating in their plan.


Figure 1

State Regulatory Agency

Ecology or DEQ

Recycling Plans/ProgramsFinanced/Run by Manufacturers

(The exception is the Oregon State Contractor Program which is run by a DEQ contractor).

Processors/Recyclers

"Processor" is term used in WashingtonRecycler " is term used in Oregon

Transporters

Provide logistics, move covered electronicsfrom collectors to processors/ recyclers

Collectors

Includes non-profit donation organizations,retailers, transfer stations, reuse organizations

Covered Entities

Stakeholders who may use the recycling systeminclude households, small businesses, andothers as specified in respective state law

ManufacturerFinancing

no visible fee

ManufacturerFinancing

no visible fee

Schematic Overview of OR and WA E-Cycle Programs

Figure 1


The manufacturer plans contract with various organizations and businesses to provide collection sites where people can drop off their unwanted equipment. The plans are required to have collection locations in all cities and counties with more than 10,000 people. The plans also contract with transporters and recyclers/processors to haul the equipment from collectors to recyclers/processors and to recycle the equipment to prepare the materials for reclaiming or reuse in new products in accordance with processing standards established by each state.

The state agencies provide program oversight and enforcement. Local governments assist with publicizing the program and consumers required bring their unwanted equipment to the collection sites.

2.1 Common Elements Within Oregon and WashingtonCommon program elements include:

• Manufacturer role: Both state programs require manufacturers of computers, monitors and televisions to finance collection, transportation, recycling, system operations and some promotion.

• Government role: The state environmental protection agencies provide program oversight, enforcement, ensure environmentally sound recycling and help advertise the program and local governments promote the program within their jursidictions.

• Scope of products: Both states require the recycling of the following “covered products:” televisions, computer monitors, desktop computers and laptop computers. Peripherals such as mice and keyboards are not included.

• Entities covered by the program: Both states require the manufacturers to provide recycling services to household consumers and small business although there are differences in the definition of “covered entities” below.

• Collection services: Both states require publically accessible collection locations in all cities of 10,000 or more, and that collection service be provided in all rural counties without cities of this size as well.

• Registration: Both states require manufacturers to register with their respective state’s environmental agency (the Oregon Department of Environmental Quality and the Washington Department of Ecology) and pay a fee to support program administration, oversight and enforcement by these agencies.

• Independent plans/Manufacturer programs: The laws in both states establish a “default” program that electronics manufacturers can participate in to comply with the requirements of the law. In addition, both state’s laws allow the manufacturers or groups of manufacturers to run their own programs independently of the default programs. These programs are subject to specific requirements in the law and the approval of state officials. In Washington, these manufacturer-run programs are called “independent plans” and in Oregon they are called “manufacturer programs”.

• Financing. In both states, the manufacturers are required to pay all program costs including administration, collection, transportation and recycling. Each manufacturer selling into the states is assessed a percentage of the overall E-Cycle program electronics that they are responsible for – this amount is called the “return share”. The return share is based on the amount, in pounds, of their brand of products that is brought in to the program to be recycled. Return shares are calculated each year by conducting a sampling of products, by brand, that come in to the processing/recycling facilities. If a manufacturer or group of manufacturers elects to operate their own independent program, they are responsible for collecting, recycling and paying for their collective percentage of products as determined by the return share. These plans are required to be self-funding and each plan assesses their members for the costs of implementing the recycling program according to their own internal arrangements.

- In Oregon the DEQ also establishes a minimum per capita collection target for the entire Oregon E-Cycle program for covered electronics. Using this per capita minimum, each approved program’s return share is translated into a minimum pounds goal for the upcoming program (see “Performance targets” in the next section for more detail).

- The financing obligation in the respective state default plans is different and is described in the next section under “Apportionment of default program costs.”


• Enforcement: All manufacturers that sell their products into Washington and Oregon are required to register with the state and participate in a plan. Those that are not participating cannot sell their products in either state. Retailers are required to check the registration lists to determine if their product manufacturers are registered and complying with the law. If retailers sell products from manufacturers that are not participating in a program, they are in violation and can be fined.

• Environmental management standards: Both states have set environmental management standards for service providers such as collectors, transporters and processors/recyclers – although these standards are not identical. Overall these differences are technical in nature. Washington has implemented its recycling requirements as regulations while Oregon has published Environmental Management Practices which all approved E-Cycle programs must meet.

• Sampling for return share: Both states require a sampling program of covered electronics entering their respective recycling systems as the basis for establishing manufacturer-specific return shares. Sampling events are generally conducted at recycler/processor facilities and include recording and tallying of product brands. Washington implemented its sampling program in 2009, Oregon began in 2010.

• Definitions: In Washington a “processor” means an entity engaged in disassembling, dismantling, or shredding electronic products to recover materials contained in the electronic products and prepare those materials for reclaiming or reuse in new products in accordance with processing standards established by this chapter and by the department. A processor may also salvage parts to be used in new products. Oregon uses the term “recycler”.

2.2 Notable Differences Between Oregon and Washington• “Default” programs: Washington’s default program is

a state-created WMMFA which is governed by a board of directors comprised of a total of eleven computer and TV manufacturers appointed by the Department of Ecology. Oregon’s default program, the State Contractor Program (SCP), is run by a contractor selected by the Oregon Department of Environmental Quality (DEQ) and has no direct manufacturer oversight.

• Independent plans/manufacturer programs: Both programs allow manufacturers to run their own plans/programs. In Washington in 2009 there were no independent plans and all manufacturers participated in the default standard plan. In late 2009, two groups of manufacturers submitted independent plans to the Washington Department of Ecology to begin operation in 2010. The plans were not approved and the standard plan will continue to be the sole plan operating in 2010. In Oregon, there were three manufacturer-run programs in addition to the default program run by the contractor.

• Return share obligations: In Oregon plans must collect and recycle, at a minimum, their share articulated by DEQ in pounds of covered electronics (not a percentage). In Oregon plans must operate throughout the year (even if they have met their minimum), and would be penalized if they did not achieve their target except for the State Contractor Program (SCP). In Washington, when or if there are independent plans, the plans would compete with each other to collect and recycle their percentage return share of electronics established by the state. Plans that fail to meet their share must pay plans that have collected more than their share a set amount per pound for the material that was collected by the other plans.

• Covered entities: Washington defines “covered entities” slightly differently from Oregon. Specifically, Washington provides access to the recycling system to “consumers” defined as any household, charity, school district, small business (defined as less than 50 employees), or small government. Oregon covers any household, small business (defined as 10 or fewer employees), 501(c)3 non-profit charities employing 10 or fewer employees, or any person giving seven or fewer covered electronic devices to a collector at any one time.

Oregon State Senators Jackie Dingfelder and Frank Morse at the Oregon E-Cycles’ kick-off event in February 2009.


• Reuse and Refurbishment: In Washington, reuse and refurbishment can be done at the processor/recycler facility or at the collector facility. The refurbishment activity by collectors is now allowed due to a 2009 amendment to the law. In Oregon reuse and refurbishment may only be done by collectors. The number of units diverted for reuse is reported by the programs to DEQ quarterly. There is no reporting requirement for reuse in Washington.

• Registration: In Washington all collectors, recyclers and transporters must register with the state. No such service provider registration requirement exists in Oregon.

• Manufacturer Plan requirements: In Oregon all plans are free to choose any service provider to comply with various requirements (e.g., hiring collectors in every city of 10,000 or more). In Washington the default WMMFA must work with any collector registered with the state and must “fairly compensate” those service providers. In both states, service providers must meet environmental management practices which are established in each state.

• Administrative rules: Oregon has implemented the first year of its program without rules, relying on the statute and several guidance documents which had been developed through a consensus process in an advisory committee of stakeholders. Documents include the following guides: Guide for Manufacturer Recycling Plans; Environmental Management Practices; and Collection System Standards (see www.oregonecycles.com). Washington enacted regulations in 2007 that can be found at http://www.ecy.wa.gov/pubs/0707042.pdf.

• Disposal ban on computers, monitors, TVs: Oregon has a disposal ban which became effective on January 1, 2010 (one year after the collection programs began operating).

• Performance targets: In late 2008 and after discussions and negotiations with manufacturers about a number of issues, Oregon DEQ set a minimum 3.3 lbs. per capita collection target for the entire Oregon E-Cycle program for covered electronics. This minimum per capita collection target translated to more than 12 million pounds to be collected statewide in 2009 across all programs. No such minimum target was established in Washington, but even without setting any such quantitative target per capita collection results during the first year of operation are very similar across both states: actual collections in Oregon in 2009 were at 5.13 lbs. per capita, and were 5.88 lbs. in Washington. Both states also have a convenience requirement to provide collection services in each county and at least one ongoing collection site in all cities with a population of 10,000 to ensure that the service is accessible and convenient.

• Apportionment of default program costs: In Washington the WMMFA Board establishes financing policy for all WMMFA members and has established a financing policy based on a combination of market share and return share. In 2009, there is a 50-50 split between market and return share which shifts to full market share over time. As there are no independent plans in Washington to date, this financing policy is effectively the statewide financing approach. In Oregon the law specifies that TV manufacturers participating in the State Contractor Program (SCP) pay according to their respective market share of all TV manufacturers in the SCP, while manufacturers of desktops, laptops and monitors in the SCP pay according to their return share. In Washington the WMMFA bills WMMFA members quarterly to cover its operating costs while Oregon DEQ bills manufacturers participating in the SCP with an initial estimated bill and then a true up bill after the year closes. Both organizations must account for non-paying manufacturers due to bankruptcy or non-compliance. Because it bills quarterly, WMMFA can adjust for non-paying manufacturers more quickly than Oregon DEQ.

2.3 Description of Entities Responsible for Implementing Recycling Plans

For the initial E-Cycling program year Oregon DEQ approved four recycling plans: the Electronic Manufacturers Recycling Management Company LLC (MRM) plan, the Independent Producer Responsibility (IPR) plan, Dell and the “default” State Contractor Program (SCP). DEQ hired a contractor – the National Center for Electronics Recycling (NCER) – to run the SCP, which is Oregon’s default program. Washington had a single approved recycling plan in 2009, the default program operated by the WMMFA.

www.oregonecycles.com


2.4 Processing (Recycling) InfrastructureThe default plans in both states use multiple processors/recyclers. Consistent with the legal requirements the WMMFA contracts with any qualifying processor meeting the voluntary Preferred Standards published by the Washington State Department of Ecology (see document #07-07-046) and referenced in Washington regulations published at WAC 173-900, see http://www.ecy.wa.gov/biblio/0707042.html. This requirement was a policy decision of the WMMFA Board of Directors. Currently the WMMFA has eight approved processors/recyclers with facilities in Washington, Oregon and California.

In Oregon the SCP issued open Requests for Proposals in 2008 and in 2009 stipulating requirements, including conformance with Environmental Management Practices (EMPs) published by DEQ, see http://www.deq.state.or.us/lq/pubs/docs/ORECyclesEnvironmentalManagementPractices.pdf. As of this writing the SCP has contracts with four recyclers with facilities in Oregon, Washington and California.

Independent manufacturer programs in Oregon contract with recyclers privately; some programs contract exclusively with one recycler, others use two or three. In all cases, the recyclers are required to meet the Oregon EMPs or a different standard which is equivalent or better, as approved by the DEQ.

Graphics depicting the respective Washington and Oregon recycling plans/programs are shown in Figures 2 and 3.

Figure 2

Washington Materials Management andFinancing Authority (default program)Governance Structure December 2009Approximately 210 manufacturers participating

ErikStromquist,

CTL

SusanWright,Osram

Sylvania

WMMFAJohn Friedrick ,

Executive Director

From the statute: "Five board positions are reserved for representatives of the top ten brand owners by returnshare of covered electronic products....including at least one board position reserved for a manufacturer who is

also a retailer selling their own private label."

MikeWatson, Dell(Vice Chair)

TalalEl-Husseini,PC Systemsand Services

MaryJacquest,Lenovo

(Secretary)

Mark Dabek,Re-PC

GreggChason, P&F

USA

Nick Amman,Apple

(At-LargeExec Cmte)

StaceyWard,

Wal-Mart

Megan Ehret ,Thomson

(Treasurer)

Figure 2

Total Reclaim recycles electronic equipment for both the Oregon and Washington programs.

http://www.ecy.wa.gov/biblio/0707042.html

http://www.ecy.wa.gov/biblio/0707042.html

http://www.deq.state.or.us/lq/pubs/docs/ORECyclesEnvironmentalManagementPractices.pdf

http://www.deq.state.or.us/lq/pubs/docs/ORECyclesEnvironmentalManagementPractices.pdf


Figure 3

2.5 Collection InfrastructureThe plans in both states have contracted directly with collectors, or through their recyclers, who operate the staffed collection locations required by law. Collection sites must be located in cities over 10,000 in population and in all counties and operate according to environmental management standards.

In Washington, collectors must first register with the Department of Ecology and then develop arrangements with the WMMFA on a fair price and logistical arrangements. There are no restrictions on the number of collectors working for the WMMFA in any local jurisdiction and all registered collectors are entitled to provide service to the WMMFA, subject to agreement on fair compensation and operational arrangements. The logistics strategy employed by the WMMFA and contracted transporters is designed to take advantage of existing shipping activities operating below capacity (e.g., backhauling) to lower costs and, as a side benefit, avoid generation of new greenhouse gas emissions.1

1 A transporter interviewed for this study noted that nearly all shipments in both Washington and Oregon are “backhauls” so they are not moving empty trucks to collect covered electronics.

Approved 2009 Oregon ProgramsOperational Structure in Each Program

MRM

Program Management:Environmental

Practices41% RSBW

Panasonic,Sharp,Toshiba

16additionalTV mfrs

State ContractorProgram

Program Management:NCER , ZWA33% RSBW

173participating

mfrs

IPR

Program Management:Waste Management

Recycle America19% RSBW

Acer/Gateway LGSony

Dell

7% RSBW

Dell

Figure 3

RSW = Return Share By Weight

Customers bring their computer equipment to Ace Metal Company in Snohomish County Washington.


In Oregon there is no registration requirement. The SCP contracts directly with collectors but on a more selective basis – there is no obligation for the SCP to hire additional collectors in jurisdictions where the minimum collection requirement has been met. The Oregon SCP also negotiates compensation rates consistent with the market for collection services.

Some independent manufacturer programs in Oregon have made arrangements with collectors in a variety of ways, either contracting directly with collectors, requiring their contracted recyclers to hold agreements with collectors, and/or have agreements between manufacturer programs to share sites. Transportation services under the programs vary widely, from services provided by the program, by the recyclers or by the collector “self-ship” arrangements to use of common carriers.

In Oregon many collectors have contracted with more than one program and are free to choose which program receives covered electronics collected at their facility (note that several transporters and recyclers also work for multiple programs). Other collectors are shared via program-to-program agreements. In this case, a collector has an arrangement with only one program but that program’s “pounds” are shared with another program via arrangements between programs. So from the collector’s perspective it is sending covered electronics to only one program, but the collection/recycling cost and weight are shared with the another program.

These arrangements have developed for the convenience of the program in finding collection sites across all required jurisdictions, particularly when collecting sufficient amounts of covered electronics to meet the minimum target is not a concern to programs. As programs reached and exceeded their per capita collection target in 2009 shared collectors were encouraged to use other programs. The dynamics of a lower per capita collection target in 2009 as it relates to shared collectors is expected to change in 2010 when a higher per capita collection target goes into effect.

3.0 Summary of Program DataBoth programs started strong during the first three quarters of 2009, both in terms of collection amounts and the number of collection locations. Members of the public and other covered entities could access more than 450 collection locations across Washington and Oregon (see Appendix 1 and 2 for a list of collectors active during Q1 through Q3 2009 in Oregon and Washington, respectively). Collection amounts for the first month exceeded per capita results during start-up periods in other states such as California in 2005 and Maine in 2006, and were at a rate similar to amounts collected in Minnesota (2007/2008).

Tables 1 through 5 provide key program data from each state.

Table 1: Total Pounds of Covered Electronics Collected and Recycled in 2009Quarter 1 Quarter 2 Quarter 3 Quarter 4 TOTAL 2009Pounds Pounds Pounds Pounds Pounds Pounds/Capita

Washington 9,118,843 9,655,152 10,856,640 8,918,039 38,548,674 5.89Oregon 4,938,541 4,604,814 4,808,600 4,471,182 18,971,795 5.13

Table 2: Type of Covered Electronics Collected and Recycled2009 Total

Televisions Monitors ComputersWashington 58% 32% 10%Oregon 57% 32% 11%


Table 3: Oregon-Specific, Program-Specific Recycling Results (lbs)% Responsibilityof 3.3 lbs/capita

program minimumQ1 Q2 Q3 Q4 Total 2009

(lbs. and % of total)

Dell 7% 897,490 819,420 809,771 827,323 3,354,004 18%IPR 19% 743,374 623,711 577,994 633,159 2,578,238 14%MRM 41% 2,281,327 1,832,198 1,827,915 1,478,504 7,419,944 39%SCP 33% 802,368 1,539,000 1,746,045 1,532,196 5,619,609 30%

Table 4: Oregon-Specific Reuse Amounts in 2009 (in units)

Q1 Q2 Q3 Q4* TOTAL 2009*

Units Diverted for Reuse 8,983 7,811 8,449 668 25,866

*Totals from the last quarter are not complete.

Table 5: Washington-Specific Details (lbs) through 20092009 Totals

TELEVISIONSHousehold TV 22,157,784School District TV 64,740Small Business TV 128,088Total TELEVISIONS 22,350,612MONITORSHousehold Monitors 11,536,361School District Monitors 619,220Small Business Monitors 105,375Small Government Monitors 22,778Total MONITORS 12,287,734COMPUTERS (includes laptops)Household Computers 3,593,279School District Computers 296,463Small Business Computers 15,899Small Government Computers 4,687Total COMPUTERS 3,190,328Total pounds CEPs 38,548,674


Table 6: Washington CEP Pounds by County through 2009

WA State County Population Population

% of State

Estimated quantity in pounds by WA State county

Percent of total pounds by county

Adams 17,285 0.3% 28,103 0.1%

Asotin 21,420 0.3% 105,662 0.3%

Benton 163,058 2.5% 531,031 1.4%

Chelan 71,540 1.1% 277,392 0.7%

Clallam 71,021 1.1% 417,463 1.1%

Clark 424,733 6.5% 1,631,456 4.2%

Columbia 3,990 0.1% 24,211 0.1%

Cowlitz 101,254 1.6% 460,493 1.2%

Douglas 36,653 0.6% 30,531 0.1%

Ferry 7,353 0.1% 19,002 0.0%

Franklin 72,783 1.1% 28,764 0.1%

Garfield 2,060 0.0% 15,478 0.0%

Grant 84,697 1.3% 224,432 0.6%

Grays Harbor 71,342 1.1% 253,974 0.7%

Island 81,424 1.2% 433,480 1.1%

Jefferson 29,542 0.5% 113,498 0.3%

King 1,875,519 28.6% 14,897,664 38.6%

Kitsap 239,769 3.7% 1,738,263 4.5%

Kittitas 38,951 0.6% 375,765 1.0%

Klickitat 20,377 0.3% 32,100 0.1%

Lewis 74,132 1.1% 288,108 0.7%

Lincoln 10,344 0.2% 30,824 0.1%

Mason 57,846 0.9% 279,990 0.7%

Okanogan 40,033 0.6% 78,313 0.2%

Pacific 21,271 0.3% 74,537 0.2%

Pend Oreille 12,859 0.2% 30,654 0.1%

Pierce 785,639 12.0% 4,405,285 11.4%

San Juan 15,294 0.2% 35,006 0.1%

Skagit 118,000 1.8% 501,009 1.3%

Skamania 10,794 0.2% 40,982 0.1%

Snohomish 683,655 10.4% 5,495,051 14.3%

Spokane 462,677 7.1% 1,702,177 4.4%

Stevens 42,050 0.6% 70,154 0.2%

Thurston 245,181 3.7% 1,507,710 3.9%

Wahkiakum 4,133 0.1% 12,635 0.0%

Walla Walla 57,788 0.6% 265,245 0.7%

Whatcom 196,529 3.0% 1,111,034 2.9%

Whitman 41,664 0.6% 179,360 0.5%

Yakima 234,564 3.6% 805,838 2.1%

Total 6,549,224 38,548,674 100.0%

Table 7. Oregon CED Pounds by County for 2009, as reported by recycling programsRow Labels Sum of Total Pounds

Baker 32,556

Benton 578,136

Clackamas 2,006,380

Clastop 4,631

Clatsop 70,827

Columbia 210,650

Coos 227,154

Crook 37,490

Curry 81,293

Deschutes 1,192,551

Douglas 304,656

Gilliam 1,542

Grant 23,574

Harney 82,254

Hood River 120,977

Jackson 830,283

Jefferson 26,875

Josephine 477,875

Klamath 109,148

Lake 22,615

Lane 2,022,959

Lincoln 175,375

Linn 375,064

Malheur 15,708

Marion 1,077,005

Marion 234,273

Marion/Polk 569,142

Morrow 18,938

Multnomah 3,889,880

Polk 353,328

Sherman 1,567

Tillamook 142,737

Umatilla 228,777

Union 97,385

Wallowa 17,137

Wasco 135,439

Washington 2,877,859

Wheeler 7,532

Yamhill 288,732

Grand Total 18,970,304.00


4.0 Summary of Stakeholder InterviewsThe consulting team interviewed 38 stakeholders involved in the implementation of the Washington and Oregon E-Cycle program in November and early December, 2009. Stakeholders interviewed included:

• Regulators (public officials) of the respective state systems

• Plan/program managers implementing collection/recycling programs

• Manufacturers involved in financing and/or overseeing program implementation

• Private solid waste companies in and out of the program

• Local government solid waste officials

• Processors/recyclers in and out of the program

• Environmental Non-Governmental Organizations (NGOs)

• Refurbishment/reuse Organizations

• Transporters

These stakeholders were asked to comment and provide insight on a range of issues relevant to the development and first ten months of implementation of the E-Cycle programs. Because of the small number of stakeholders interviewed in each category, these findings are not statistically significant. However, they do provide a useful temperature check after the first year of program operation and provide information to consider as the programs evolve.

As expected, consensus across all respondents was rare on any issue. But there are also clear trends articulated by respondents on some specific issues – sometimes across a stakeholder category, sometimes geographic – and those trends are discussed below.

On many issues responses from stakeholders did not vary considerably across states. Where responses did vary it is noted in the text.

Noteworthy comments are summarized below under the following topic headings:

• Program Operations

• Environmental Program Impacts

• Policy Issues

• Economics

Although 38 stakeholders were interviewed for this study, not every stakeholder interviewed was asked every question (e.g., collectors were not asked about the manufacturer financing allocation process). Appendix 3 provides a list of the questions asked of the stakeholder groups. Observed trends within or across stakeholder groups, and summaries of findings are also provided in the following sections. Appendix 4 summarizes the number of stakeholders interviewed by stakeholder grouping.

4.1 Feedback on Program Operations All stakeholders were asked to comment on what was working well and what was not under the programs. The vast majority of respondents indicated the overall initial operational success was a notable achievement of the E-Cycle programs. Many respondents cited the number of active collectors and the quantity of covered electronics recycled as evidence of overall program success.

Respondents were positive about both Washington and Oregon. Many Washington respondents were especially complementary of the operational achievements accomplished by the WMMFA and its Executive Director.


4.1.1 Perceived Satisfaction of the Program Amongst Key StakeholdersThe majority of respondents expressed satisfaction with the programs as implemented to date. When asked to articulate what is working well and what is not, and whether the programs have met or exceeded expectations, respondents in both states cited evidence of success including:

• The quantity of covered electronics collected has exceeded nearly all expectations.

• The number of “glitches” experienced is fewer than expected for a program as new and comprehensive as E-Cycle.

• Extensive use of local collection infrastructure, particularly the use of larger charitable organizations who stated their overall satisfaction with the program.

• The system is operated and managed by the private sector and not the government (also cited as a negative by a few stakeholders).

• All government officials at the state and local level interviewed lauded the new system.

Within stakeholder categories, some program satisfaction trends noted by interviewees were mixed, including:

• Collectors participating in both programs expressed satisfaction with the program. Some collectors in both states that are not participating cited concerns about program direction (see below).

• Processor/recycler sentiment varied. Some described the program as “a great thing” and gave it high marks, while a few others expressed concern about the harsh competitive climate brought about by the E-Cycle programs. Of the eight processors/recyclers interviewed, those working in Oregon gave a slightly more favorable assessment than in Washington.

• Reuse and refurbishment organizations were particularly divided, ranging from “surprised at how well we are able to work with the system” to “the whole program stinks for refurbishment/reuse organizations.” Note that this division did not fall along state lines, rather other factors seem to be involved (see section 4.1.5 below for details)

• Manufacturers noted the successful collection amounts but most complained about several program requirements in both states as overly prescriptive. A typical manufacturer opinion in Washington was “Most of the problems in Washington are inherent in the legislation and implementation therefore requires a lot of overhead and it’s extremely complicated…management of the board and the overhead [at a state-specific level] are overkill.” Collection service requirements in both states (i.e., staffed collection in every city of 10,000) were also a frequent target for criticism as overly prescriptive and burdensome.

4.1.2 Other Overall Operational IssuesWhen asked whether there were noteworthy challenges at start-up, or whether the E-Cycle programs had resulted in significant operational changes, several service providers in both states noted the increased importance of training collector staff, having adequate collection equipment (e.g., shrink wrap and/or gaylords) and adequate storage space.

Very few stakeholders interviewed reported significant operational changes in either state other than accommodation of larger amounts of electronics. Some service providers in both states noted increased tracking and scrutiny of covered electronics than before system start-up. However, as described in 4.1.5 below, some refurbishment/reuse organizations in both states did report significant operational challenges with the transition to E-Cycle program participation.

“The biggest surprise for me was that we were right – we did have to lay out a lot of detail in the law and rules, because many players would have otherwise tried to short-cut, diminish or undo the system. We saw attempts even with the detail that was established. Hopefully this will change in the future as EPR systems are more commonplace.” (local solid waste official)

“Nice people we would not have met without the program. Also this has helped reduce our provincialism. A very positive thing.” (Oregon collector)


Historical Issues from Washington Program Startup in 2007

Specific to Washington, at a management level one stakeholder noted some key challenges at the very beginning of the program. In January, 2007 the Department of Ecology appointed the initial members of the WMMFA Board of Directors. The WMMFA Board organized itself and began execution of key tasks: hiring legal counsel, budgeting and scoping out possible operational strategies.

Resources for executing these tasks were scarce and came primarily from in-kind staff support provided by the Department of Ecology, and the National Center for Electronics Recycling (NCER) as a follow-on to a study of a possible joint Washington/Oregon “third party organization” conducted for the Northwest Product Stewardship Council in 2005. The Department of Ecology’s in-kind support was accounted for as a loan to the WMMFA and NCER support was provided using external grant funds obtained by the NCER from U.S. EPA and the Consumer Electronics Association.

At the time the legislative battle in Washington was still fresh and some opponents continued to question the viability and legality of the WMMFA. Questions about the WMMFA legal standing raised by one of these opponents during the spring of 2007 resulted in the WMMFA Board “re-doing” all of its actions from previous meetings, including the election of officers and hiring of legal counsel.

Drawing from these experiences one stakeholder had these concrete suggestions:

• “For a default plan like the WMMFA it’s critical to know the legal status of the entity – what are you subject to as a private entity or a public agency? Does the open meeting law apply? That should all be clear at the beginning to avoid the legal costs and questions. During the first few months of the WMMFA certain industry lobbyists forced re-election of officers and for the WMMFA to completely start over, and these folks really wanted it to blow up at first but that didn’t happen.”

By August, 2007 most of these legal questions had been resolved and a $500,000 loan had been appropriated by the Washington legislature upon a special request of the WMMFA to cover pre-implementation expenses, including drafting of the initial Standard Plan and the WMMFA Operating Plan by the statutory deadlines. This stakeholder further noted that “any new system should learn from our experiences – startup was shaky and we went through a lot to sort out our legal status and scrape together funds to get started, and hopefully any new system can start on firm footing.”

4.1.3 Specific Operations Issue: Management of Materials from Covered Entities vs. Non-Covered Entities

Responses to the question of how collectors were managing the distinction between covered and non-covered entities varied. As noted above, Washington provides recycling system access to the following covered entities: “consumers” defined as any household, charity, school district, small business (defined as less than 50 employees), or small government. Oregon covers any household, small business (defined as 10 or fewer employees), 501(c)3 non-profit charities employing 10 or fewer employees, or any person giving seven or fewer covered electronic devices to a collector at any one time.

• Several respondents across stakeholder types and states suggested that the program would be easier to administer if the program only covered household sources of equipment.

• Some respondents in both states cited this issue as a more complex challenge when there are multiple plans. With only a single plan it is easier to spot anomalies in collection amounts/splits from a single collector than when the collector can ship to multiple programs.

• Specific to Oregon, several respondents cited the use by collectors of the “seven or fewer” units screening criteria option for anyone dropping off covered electronics as an easy alternative to determining generator status. While this opinion about the “seven or fewer” approach was popular it was not unanimous. A single Oregon collector who operates both inside the program and outside of the program (and charges a fee to accept those electronics) described the situation as “terrible” and “almost impossible to do” citing the additional burden in communicating the rules to customers and the changes now required in handling incoming electronics to differentiate covered from non-covered.

There were no notable differences across stakeholder types queried on this topic.


4.1.4 Specific Operations Issue: Management of Covered Electronics vs. Non-Covered Electronics

The scope of electronic products covered by the programs is the same in both states: televisions, computer monitors, desktop computers and laptop computers. A large majority of respondents expressed a desire to include peripheral computer products of all sizes in the program. Although several service providers reported that they had developed systems to keep peripherals out of the program and that was working well, more common were responses expressing a desire to include keyboards, mouse devices, printers and other peripherals as covered electronics.

• An Environmental NGO respondent was strongly in favor of adding peripherals and “anything with a circuit board” to E-Cycle program because 1) manufacturers are pushing recyclers to take these for free and further squeezing recycler margins, 2) metal recyclers are collecting non-covered electronics and managing them without consideration to responsible management, 3) public brings in other items and collectors feel they must provide an option to handle it for their customers, and 4) other products have same or similar materials of concern, toxicity or resource value.

• Similarly several other respondents suggested that the program should be gradually expanded, and a local solid waste official suggested the ultimate product scope should be “similar to the Waste Electrical and Electronic Equipment (WEEE) Directive in Europe and emerging programs in Canada.”

4.1.5 Specific Operations Issue: Reuse and RefurbishmentAs noted above, in Washington reuse and refurbishment activities can be conducted by the collector or the processor/recycler, including refurbishment activity by collectors following an amendment to the law. The amended law allows collectors to repair computers using whole parts gleaned from collected computers or new parts for making repairs as long as there is a part-for-part exchange with nonfunctioning computers submitted to a plan (http://apps.leg.wa.gov/documents/billdocs/2009-10/Pdf/Bills/Session%20Law%202009/1522-S2.SL.pdf).

In Oregon reuse may only be done by collectors and the number of units diverted for reuse is reported by the programs to DEQ quarterly (see Table 4 in Section 3). There is no reporting requirement for reuse in Washington.

Refurbishment/reuse organizations across both states expressed widely diverging views on the E-Cycle programs and how they have been implemented in both states. One area of consensus across refurbishment/reuse organizations (and other stakeholders who volunteered similar suggestions) is that the E-Cycle programs should enhance public awareness of reuse opportunities by identifying reputable collectors.

Reuse Experience in Oregon

A refurbishment/reuse organization in Oregon that is now qualified to do limited recycling (i.e., desktop dismantling for units donated to them by covered entities) for one of the programs provides a successful case study. In their experience, becoming qualified to recycle was difficult and expensive due to the relatively high recycling performance requirements such as on-site pollution liability insurance, auditing/due diligence of

There are 96 Goodwill sites in Washington and 62 in Oregon serving as E-Cycle collectors.

http://apps.leg.wa.gov/documents/billdocs/2009-10/Pdf/Bills/Session%20Law%202009/1522-S2.SL.pdf

http://apps.leg.wa.gov/documents/billdocs/2009-10/Pdf/Bills/Session%20Law%202009/1522-S2.SL.pdf


downstream processors, and implementation of an active environmental management system (EMS).

Also, meeting program requirements beyond these environmental performance measures – including tracking all incoming electronics as covered or not throughout the facility – was and is time-consuming for all refurbishment/reuse organizations regardless of whether they are qualified by a program to recycle covered electronics or not. Income from the sale of dismantled desktop units was cited by this Oregon refurbishment/reuse organization as critical for continuation of mission activities associated with refurbishing used electronics. This recycler qualification step is a very high bar and was pursued and met by only one Oregon refurbishment/reuse organization in 2009.

In contrast to that experience, another Oregon refurbishment/reuse organization that is not qualified as a recycler noted that prior to program rollout their finances were stable enough that they routinely gifted refurbished electronics (e.g., they formerly charged Social Services only $50 for an Internet-ready machine, and now have had to increase the cost to $100). When they stopped recycling covered electronics at their facility they experienced significant reductions in revenue. Their recycling activity was also an element of their training program, and that has also suffered as a result.

Prior to the Oregon E-Cycles program this refurbishment/reuse organization said they “spent 10 years as a non-profit educating the community to take responsibility for what they consume” and opined that generally people were happy to drop off material and pay $15 per monitor and $1 per inch for TVs, but that when the program began “that sense of responsibility went away and now it’s the government’s job.” But even through the disappointment this refurbishment/reuse organization noted that they preferred Oregon’s more liberal reuse policy and that “DEQ is doing an adequate job promoting reuse, certainly better than some programs I’ve seen.” One clear benefit of the Oregon reuse policy for this refurbishment/reuse organization is that “we are allowed to pull out whatever we think we can use and that’s good.”

Reuse Experience in Washington

Similar to the Oregon experience, a Washington refurbishment/reuse organization that still refurbishes some electronics without qualifying as a processor/recycler expressed disappointment with the Washington E-Cycle program. The biggest problem cited by this refurbishment/reuse organization is the lack of electronics flow – “I get no material and I’m sending volunteers away.” Other collectors are more convenient to more consumers, and this refurbishment/reuse organization no longer has the competitive advantage of offering free recycling when most other collectors charged a fee.

This refurbishment/reuse organization cited the genesis of the problem as the regulation mandating that a non-functioning computer had to go to recycling – “that killed our business since everything coming in has something wrong with it. And the amended law did not fix the problem.”

In contrast another Washington non-profit that collects for recycling and resells some covered electronics that still have reuse value – without refurbishing – did not cite those concerns. This charity said they would like to see non-profits that refurbish and reuse electronics promoted more. Furthermore, they “have a note on our website that if folks have computers for donation that are above a specific threshold they take them to a non-profit refurbishment organization.”

A local solid waste official noted that more can be done to increase reuse even among the refurbishment/reuse organizations currently participating in the program and already receiving lots of units. This official said there needs to be training on triage, data security, and repair – this is an area ripe with job opportunities.

Finally, of note is an observation by a recycling plan manager in Washington that the amended law has resulted in more gutted computers arriving at his contracted recyclers (i.e., the more valuable components have already been removed).

4.1.6 Collector Participation and CompensationAs noted above there are now hundreds of collection locations participating in the E-Cycle programs across both states. Reasons for not participating included perceived lack of adequate compensation and other program operational requirements such as lack of room to palletize/shrink wrap collected electronics. One collector suggested that a more detailed handbook


for different types of collectors would be helpful. Most, but not all, participating collectors interviewed said compensation was adequate. Of the two entities interviewed that were not participating in the program, one said the compensation was too low. Both non-participants interviewed cited that they either had no storage space or public accessibility to the site was limited and/or that their facility had physical limitations that would make being a collector too difficult.

Note that in Washington the law requires that Ecology annually solicit feedback from local governments and communities on how the E-Cycle program is working in their communities, and this feedback process is expected to take place during the next few months. Once such feedback is published it will likely provide additional insight into the performance of the Washington program not available in this study.

Collector Differences in Washington versus Oregon

There is a notable difference between Washington and Oregon concerning the participation of transfer stations and associated private solid waste companies. In both states these transfer stations typically collect solid waste and recyclables from local haulers. In many cases, particularly less populated areas, the transfer station owner or operator also provides the hauling service.

Transfer stations typically have transport capabilities integrated into their operations and/or are closely aligned via ownership or legal agreements with private solid waste collection or hauling companies that operate within that locality via franchise agreements. Most transfer stations also manage recyclables at their facilities.

In Washington very few transfer stations with transport capability are registered collectors. In Oregon, most counties have at least one transfer station working as a collector for at least one of the approved plans.

In Washington one non-participating transfer station operator focused on the role, or lack thereof, of curbside collections2 and compensation amounts:

• “Haulers like us who are collecting these materials curbside are not able to get compensated enough to cover our costs. This should be the first option for management of most of these covered electronics as it takes advantage of existing infrastructure (trucks are already on the road) and avoids the environmental impact of unnecessary vehicle trips to drop-off facilities.”

• “We are not a drop-off-for-free site because the reimbursement rates are not high enough to cover our costs. We have storage costs, handling, and are not set up to manage a lot of people coming in the front door. It’s unlike some larger non-profits where they are used to having folks drive up and drop off material and have space to palletize, but for an operation like ours where we have a shop and an office it’s not the same kind of mass production facility like they can do.”

According to several respondents many transfer station operators were interested in participating but either could not agree upon a rate near what other collectors in that locality had agreed to, and/or the transfer station did not have the transportation infrastructure, or, correct equipment to participate (e.g., some transfer stations offered to collect and transport covered electronics in their roll-off or open top 40 yard containers that do not meet program requirements). Similarly, public transfer stations and King County and Snohomish County, Washington decided not to participate because they are not a good fit for collection activities and private sector collectors are expected to operate more effectively and efficiently. Local officials in the Seattle area also noted that most consumers would much rather visit a non-profit donation organization than go to a transfer station.

In Oregon, transfer station operators are participating as collection sites responded differently as illustrated in the following response:

• “I’d like to have more covered electronics be collected here but I find [compensation amounts] to be adequate. As a stand-alone activity it would not work, and it breaks even barely.”

2 Note that the Washington law allows the haulers or cities who provide the curbside services to cover their collection and transportation costs in any number of ways. They can raise trash collection rates overall, or they can charge a specific pickup fee for each customer that wants to use the service – rather than increasing the entire garbage rate for a few people that want to use the curbside service. Some jurisdictions such as the city of Seattle are doing this even though they are not participating directly in the E-Cycle program – they offer their curbside customers the opportunity for pickup and they bill them individually for each pickup.


Beyond these differences there were also differing opinions on the Washington collector registration system (where anyone can be a collector subject to negotiation of fair compensation with the WMMFA) and the Oregon collector contracting system. By and large most stakeholders in their respective state expressed a preference for the structure of collection services in their state.

The notable exception was concern from two collectors in Washington about the lack of adequate free market elements in this system – basically there is only one “buyer” of collection services in Washington (the WMMFA) and collectors who wanted to stay in the program have no other choice. And in Oregon one service provider interviewed complained about not being able to participate in the Oregon E-Cycles program (programs in Oregon may, but are not required to hire any service provider meeting E-Cycles requirements).

Manufacturer Comments on Collection Requirements

Most manufacturers complained that the requirement in both states that there must be at least one staffed collection site in every city of 10,000 population and service in every county as overly burdensome. This requirement is unique to Washington and Oregon’s programs and some manufacturers stated preference for the service requirements in other states’ producer responsibility programs.

For example, in Minnesota and in other states, collection responsibility rests with individual manufacturers, not with a statewide manufacturer plan/program. Each manufacturer is responsible for arranging collection and recycling of an amount of electronics specified by the state – usually through contracted processors/recyclers – and all urban areas and many, but not all rural counties have at least one manufacturer-financed collection opportunity. Consistent with this “individual producer responsibility” approach each manufacturer selling into Minnesota is given a “pounds recycled” target with a bonus for collecting electronics outside urban areas. Manufacturers of all sizes typically negotiate arrangements with a processor/recycler to receive credit for recycling the number of pounds the manufacturer is required to recycle without regard to the specific collection location or means of collection (e.g., an event).

In their first program year Minnesota had approximately 150 different collection locations – a significant number but not as many as in Washington and Oregon. As for per capita collections Minnesota recorded 5.88 pounds in the most recent program year which is very similar to collection rates in Washington and Oregon. Wisconsin recently enacted a Minnesota-style electronics recycling law, as did Indiana earlier in 2009.

Sharing of Collectors

About half of the stakeholders with an opinion on this topic (mostly Oregon stakeholders as there has been only one approved plan in Washington) expressed clear support for collectors to work with multiple programs. Note that there are two distinct ways that collectors are shared across programs. First, a collector could have individual contracts with multiple programs. Another variation is that one program may contract with a collector, and then share those material pounds and collection costs with other programs via a program-to-program agreement. Those who supported this “shared collector” approach cited arguments such as the following:

• There is a limited number of potential collectors in more rural areas and sharing may be a necessity there.

• It is good for individual collectors to have choices about who receives their collected electronics.

• Entities who want to work with each other should be allowed to do so.

Others expressed concern about the shared collector approach:

• Concerns about data reporting integrity, particularly when collectors were only obligated to one plan but that plan “shared” the collector with other plans. One stakeholder noted that some collectors were not aware of this arrangement in the first year, which hypothetically prevented the collector from negotiating a separate collection payment rate or varied services with the program(s) that “piggybacked” on the one direct arrangement with the collector.

• A transporter noted that in Oregon there were numerous instances of confusion over the responsibility of shipment authorizations. The transporter cite two reasons for this: 1) there is no consistency of Bills of Lading (BOLs) across manufacturer programs in Oregon, and 2) collectors are not appropriately trained on how to ship within the system. This


has led to invalid BOLs and shipments billed to the wrong program.

• Shared collectors could play one plan/program off another (e.g., a price war for collected product).

• If collectors were not allowed to work for multiple programs there would be more collection locations for the public.

• The legitimacy of plans claiming to have collectors in a geographic locale (a “signed-on, shared collector) when in fact that collector might not actually send any units to the plan or not on an ongoing basis.

Overall, manufacturers and manufacturer plan/program managers supported sharing of collectors while government officials and default (state-created) plan/program managers expressed more questions about this practice. There was no consistent trend across other stakeholder types on this issue.

4.1.7 Economic Impacts on Processors/RecyclersMost of the comments on the economic impacts of the programs related to processors/recyclers, and many of those comments noted a negative impact. Some recyclers expressed concern about the increased financial pressures resulting from the E-Cycle systems.

The long-term ability of service providers to thrive under a producer responsibility system is untested. Given the current economics of recycling electronics where recycling these products does not pay for itself and a subsidy is required, recycling systems like these are a manufacturer’s cost to be minimized. Theoretically the less equipment that is collected and recycled, the less costs to be incurred by manufacturers. This dynamic works to drive down prices that recyclers can charge for their services, and lower prices often bring lower profit margins. Thus one recycler noted there is not a very strong incentive to invest in the industry and contrasted these economics with the garbage industry “where everyone gets their own turf via the G-certificates” and service providers can make a reasonable profit under utility-like regulation to provide an incentive to invest in their physical plant, new technologies, etc.

Overall the short-term results are mixed: while some processors/recyclers and other stakeholders expressed concern that the new system has resulted in a negative financial impact on processors/recyclers, others with newly established facilities in the region expressed satisfaction with current arrangements.

As a follow-up to the stakeholder interviews all processors/recyclers were contacted for additional information concerning the economic impact of the E-Cycle program. Of the nine processors/recyclers that provided additional information, three indicated that they established their facility as a result of one or both of these programs and another acquired an existing recycling facility in large measure because of the new laws.

The following summarizes the number of net new jobs reported as a result of the Washington and Oregon E-Cycle programs:

• Number of net new employees hired by processors hired attributable to the Washington and/or Oregon E-Cycle programs at program startup (around January 2009): 140, 79 in Washington, 61 in Oregon.

• Number of net current, ongoing employees of processors attributable to the Washington and/or Oregon E-Cycle programs: 360

IMS Electronics Recycling sited a new facility in Vancouver Washington to participate in the E-Cycle programs.


4.1.8 System Promotion and AdvertisingIn Oregon the DEQ has developed template materials and conducts the Oregon E-Cycles promotion using administrative funding from manufacturer registration fees. Retailers are required to provide the Oregon E-Cycles information to customers at the point-of-sale. Approved programs in Oregon also conduct outreach by providing information to collectors who may promote their site and conduct localized advertising for events and special collection promotions. Local governments and haulers use the template materials to promote the program in their areas. DEQ hosts a website (http://www.deq.state.or.us/lq/ecycle/index.htm) as well as a toll-free number (1-888-5-ECYCLE) to provide information and assist consumers in finding the collection location nearest to them.

In Washington, promotion and advertising have been a cooperative effort of the Department of Ecology and the WMMFA, retailers, local governments and other stakeholders. Through the 1-800 Recycle Hotline and the E-Cycle Washington website (www.ecyclewashington.org) hosted by the Department of Ecology, consumers can find drop-off locations in their county. The WMMFA has published various public outreach materials such as information cards, a brochure and flyer. They are available on the E-Cycle Washington website and hard copies can be obtained from the WMMFA or Ecology. The WMMFA has also conducted various promotional and advertising activities including event promotion and program advertising on local radio and other media. In addition numerous local governments promoted the program in a variety of ways, such as via existing websites, and some undertook extensive promotion, such as handouts to all transfer station customers and direct mail to some covered entities.

Finally, officials in Washington and Oregon developed a joint E-Cycle name, logo and educational materials which saved money and provided a consistent message to consumers across states. This example of cross-state cooperation was possible because the programs are so similar operationally. Officials were, and are, able to share a many good ideas and work products to increase the efficiency and effectiveness of E-Cycle promotional efforts.

Several stakeholders commented on this topic. Several stakeholders in both states noted that there are many consumers still unaware of the state electronics program and that more signage, more promotion or “something” needs to be done. Also noted was the need to have someone responsible for overall education and outreach, particularly if there are multiple programs.

www.ecyclewashington.org


4.2 Environmental ImpactsIn addition to the topics discussed below, service providers were also queried about changes relating to their environmental practices. Nearly all cited operational changes, but did not specifically reference changes to their environmental practices.

4.2.1 Changes in Covered Electronics Flows

Nearly all stakeholders interviewed noted the increase in the flow of covered electronics into recycling channels. Most stakeholders commenting on this pointed to a reduction in disposal of covered electronics in landfills. One solid waste official noted that the quantity of electronics flowing into their three public transfer stations participating as collection sites was twice the volume of the previous year – in just the first six months, and with seventeen other participating collection sites available in the county. Beyond that, many respondents were unwilling to speculate on changes given the lack of consistent data on flows prior to program implementation, although a handful of respondents opined that the amount of electronics flowing into unaudited recycling channels (including export to developing countries) had declined since manufacturers were given system responsibility. For example, one manufacturer noted:

• “Some of these exporters have been filtered out of the system. I know we’re paying a premium for recycling services that we would not have to pay if we were exporting to developing countries but that’s a good thing.”

A few other stakeholders noted that flows were substantial prior to program implementation, albeit mostly paid for directly by consumers through drop-off fees.


4.2.2 Design for Environmental ImprovementsOne explicit objective in both the Washington and Oregon laws is to effect environmental improvements in the design of new electronics products. The first “finding” in the Oregon law reads as follows:

(1) It is necessary to encourage the design of electronic devices that are more resource-efficient, more recyclable and less environmentally toxic;

Similarly the Washington statute includes a similar finding in the first section of that law:

The legislature further finds that the system must encourage the design of electronic products that are less toxic and more recyclable.

With one notable exception, all manufacturers, recyclers and plan/program managers interviewed stated that they were unaware of any changes in the design of new products resulting from the Washington and Oregon E-Cycle programs. Some manufacturers were very strong in making this point, and one said that “redesign of

The E-Cycle programs discourage illegal dumping of electronic equipment by providing free recycling opportunities.

Dual Recycling Standards in Washington “Ecology’s publication of mandatory and preferred recycling standards was a brilliant approach that resulted in manufacturers choosing the higher standard.” (Environmental NGO)


products due to producer responsibility mandates is a 100% failure.” Manufacturers noted that the E-Cycle laws discourage manufacturers from taking back only their own products – and that even if the law did encourage same-brand take-back, the decade or more between product design and product recycling is too long a time horizon to plan in an industry as technically fluid as consumer electronics.

One manufacturer did note that there are laws in other jurisdictions that do strongly influence design decisions, including the European ROHS directive, the U.S. Consumer Product Safety Commission, California’s Prop 65. Another manufacturer noted there is no design change that can reduce the cost of collection. This manufacturer also distinguished between “independent producer responsibility” (IPR) in which each manufacturer is individually responsible for their branded products and the version of “extended producer responsibility” (EPR) in the E-Cycle programs where the manufacturer responsibility covers all brands – and opined that the findings and design outcomes suggested by both legislatures can only be achieved through IPR.

The one exception is a manufacturer (Dell) who read the provision in the Washington law and has since asked their designers to rethink how the products are designed. Washington law requires that all plans include “a description of how manufacturers participating in the plan will communicate and work with processors utilized by that plan to promote and encourage design of electronic products and their components for recycling.” During the spring of 2009 Dell published a white paper at an IEEE conference3 containing results of a recent downstream recycling partner survey and the attributes which are considered most relevant by recyclers in improving product design for environment. Through this program Dell has initiated their product designers to the fact that these products are not done when their customers are finished with them. The Washington law was cited in the article as one factor in Dell’s decision to pursue this initiative.

4.2.3 Backhauling BenefitsOne critical operational area that does not receive much attention is logistics. If implemented without due environmental consideration, the environmental impact of transporting covered electronics from collectors to recyclers could significantly diminish the overall lifecycle environmental benefit provided by the recycling system.

Two stakeholders noted the benefit to the environment and employment picture for Washington and Oregon residents provided by backhauling. In both states almost all of the pounds collected to date have had to be transported by truck to a processor. Most often these trucks originate empty at the point of collection and are then hauled back to a processor in a metro area. This means that a truck did not have to travel “empty” (a waste of fuel and needless emissions) from Seattle, for example, to a collector location in Wenatchee, for example, in order to pick up a truckload of covered electronics.

According to a regional transporter nearly all shipments in both Washington and Oregon are “backhauls” so they are not moving empty trucks to collect covered electronics.

4.3 Policy Although the focus of these interviews was on implementation experience and observations, several policy questions were asked of various stakeholders.

4.3.1 Overall Producer Responsibility ApproachAlthough stakeholders were not asked specifically about their opinions on producer responsibility as a policy approach, several respondents volunteered such comments when asked how they thought the E-Cycle programs were working. Most stakeholders who commented on this topic expressed support for the policy of producer responsibility – including most manufacturers. In fact, nearly all critical comments focused on issues relating to producer responsibility implementation in Washington and Oregon, not on the producer responsibility approach itself.

3 Dell Survey of Electronic Recyclers – Results and Analysis. Puneet Shrivastava, Scott O’Connell, Mike Watson, Dell Inc. Presented at the 2009 IEEE International Symposium on Sustainable Systems & Technology, May 19, 2009, Tempe, Arizona.


Local officials were the most enthusiastic supporters of producer responsibility in both states. Several of these local officials noted the importance in shifting burden from local taxpayers to the producers of these products, and how E-Cycle was a major step in that direction. One local official in Washington also noted that the convenience collection requirement has assured that the manufacturer provide their rural customers with service as well. Local and state officials in both states cautioned, however, against a “cookie cutter” approach to producer responsibility across different product types – especially since collection systems will vary significantly across product types due to product size, unique handling issues and existing distribution systems. One local official asked rhetorically: “Should CFLs [compact fluorescent lights] be collected at Goodwill’s or at transfer stations? Maybe, but what about Home Depot and Wal-Mart – these are probably a better choice.” Manufacturers generally supported the producer responsibility concept but some expressed concerns about specific elements of the E-Cycle programs, including:

• Concerns about the scalability and efficiency of state-specific programs (e.g., insufficient manufacturers and manufacturer representatives to populate authority boards in all 50 states as in Washington, increased program overhead to coordinate multiple manufacturers into plans in both states). This concern contrasts with positive comments from another manufacturer about the producer responsibility experience in the Washington E-Cycle program:

- Get an operational person in place at the top, task them based on very competitive deliverables and let them go. The system works. Manufacturers know how to run these things and when you put a bunch of us on a board, it will be run like a business and it’s good for the residents of the state. Hires need to be operational not political.

• Support for a collection requirement that parallels the product supply chain for new products instead of collection requirements per local political jurisdictions. This manufacturer noted that “my company has a supply chain to get products to customers, and the supply chain is the existing system of partners and service providers that most manufacturers have in place now.” If collection is required by political jurisdiction (as in both Oregon and Washington) this manufacturer suggested “the government should just tax manufacturers instead of making them set up independent waste collection systems.”

• Another manufacturer provided this pro-producer responsibility critique of the state-created plans/programs in Washington and Oregon: “The WMMFA and the SCP have both worked to retard the development of a national producer responsibility program. These institutions have allowed manufacturers to avoid the public relations and other risks inherent in producer responsibility.” According to this manufacturer, true producer responsibility only occurs when the producers themselves are directly operating a recycling program.

More critical comments were heard from a handful of service providers who noted that producers who operate at a national level are more likely to work with national, not local, players. One collector and refurbishment/reuse organization likened producer responsibility as “the fox guarding the henhouse – including squashing reuse for competitive reasons. And now the OEMs set the prices as they can send the material to whoever they want so that everyone is working for the manufacturers now and we have lost some autonomy.” And another suggested the following: “Once this initial tidal wave of e-waste passes, will the program be sustainable over time? Is there enough money and material available to make this sustainable? There is probably not enough experience to get a sense of this yet. We should give this model enough time to evaluate before we move to develop systems for other products.”

4.3.2 Connection Between Producer Responsibility and Curbside CollectionThere were no substantive comments on curbside collection from collectors and plan/program managers currently working in the program. Although this question was not asked directly, no stakeholders interviewed cited any evidence of active curbside collection of covered electronics in either state program. But one Washington collector who collects many used electronics and other recyclables curbside as a part of a larger government-franchised curbside program – and outside the E-Cycle program – raised several concerns about the lack of curbside collection of covered electronics including the philosophical underpinning of producer responsibility and its effect on other curbside collection activities.

“Federal export restrictions should be put in place as states can only go so far.” (Environmental NGO)


4.3.3 Impact of Allocation of Responsibility Across ProducersIn both states a manufacturer implementing an independent manufacturer plan outside the state-created programs is assigned responsibility for collecting and recycling a specified amount (in Oregon) or percentage (in Washington) of covered electronics.

Independent manufacturer plans are financially responsible for funding their own program, and the law does not address how they would set up the funding structure.

Manufacturers participating in the WMMFA in Washington are subject to the WMMFA financing policy which was based in 2009 on 50% market share and 50% return share.

In Oregon, several stakeholders noted a “glitch” in the law where television manufacturers participating in the SCP pay according to their market share of all television manufacturers participating in the SCP4 as opposed to return share like other TV manufacturers in the other manufacturer programs. One stakeholder noted that this glitch caused nearly all the active television manufacturers to abandon the SCP while several large computer manufacturers chose to comply with Oregon requirements through this option. Another stakeholder disagreed that this is a “glitch” at all and expressed support for maintaining this process in the law.

There was surprisingly little noteworthy commentary on how E-Cycle programs costs are allocated across manufacturers. Manufacturers, program managers and state regulatory officials were asked about this for both states. Although several stakeholders did voice opinions on whether one financing model was preferable over another, in the Washington program nearly all interviewed stated they were comfortable with allowing the WMMFA to establish a financing policy independently of the return-share percentage-based material obligation established by the Department of Ecology calculated from sampling returned covered electronics. The one exception was from a processor/recycler:

• “The sustainability of the WMMFA is a real issue. There should be a consistent policy between the WMMFA financing policy and the legally-mandated material obligation policy.”


4.3.4 Cost vs. Benefit of a Statistically Viable Sampling Program Both states include mandatory sampling in their respective laws in order to provide the basis for manufacturer-specific return shares. Although the technical sampling approach used by both programs is not identical it is very similar. In both programs a carefully managed process is used to sample randomly more than 10,000 units of covered electronics returned for recycling. The brand and weight of each unit is recorded and state officials then correlate the brand with a manufacturer.

Several stakeholders with experience in implementing sampling requirements expressed concern about the extent and expense of existing sampling requirements. About as many noted that sampling was a fair process for allocating manufacturer responsibility. Stakeholders active in Oregon manufacturer programs were particularly concerned about the expense and redundancy created by parallel sampling programs in both respective states when only a single program is probably necessary.

Manufacturers were particularly critical of DEQ’s recent decisions on sampling, including the decision to require an Oregon-specific sampling program starting in 2010 instead of using the Washington data or sampling jointly with Washington as required by law. Otherwise there were no notable differences across stakeholder types queried on this topic.

4.3.5 Single Plan vs. Multiple PlansA majority of stakeholders in Washington expressed preference for a single program (where there is only a single plan operating) while a majority of Oregon stakeholders expressed a preference for multiple programs (where there are multiple approved programs). However, nearly all manufacturers expressed a desire to have the option for manufacturers to pursue 4 For example, if half of the Return Share by Weight in the SCP is attributable to TV manufacturers, and there are three TV manufacturers in the SCP with respective market

shares of 0%, 20% and 80%, then the TV manufacturer with 80% of the market share among SCP TV manufacturers must pay for 80% of the TV Return Share by Weight in the SCP – or in this example 40% of the total SCP Return Share by Weight – regardless of the TV manufacturer’s return share.


and operate independent programs. Several stakeholders noted that whether a single plan or multiple plan system works better depends mostly on the management of the plan – and if the single plan is well-managed then independent plans may not be desirable. Most stakeholders cited the role of these default programs as beneficial during the start-up period. Some expressed a desire for an ongoing role for a default program and even suggested they should be the only program (more commonly cited in Washington) while others suggested that over time these default programs may no longer be necessary.

Within stakeholder groups there were diverse opinions on this question, except for one stakeholder group: manufacturers. All manufacturers interviewed expressed support for satisfying their compliance requirements through independent plans/manufacturer programs, or at least for the option of pursuing these plans/programs. One manufacturer cited the default, state-created programs as significant impediments to the creation of national manufacturer recycling programs. Several manufacturers noted the importance of at least having the ability to operate independently to ensure that even a single plan operates in a competitive environment and works to minimize system costs.

4.3.6 Performance Targets In Oregon, DEQ established an overall Oregon E-Cycle program target, expressed as 3.3 lbs./capita of covered electronics, in late 2008 prior to initiation of the 2009 program year. This statewide target was allocated across manufacturers and then aggregated into each program’s total Return Share by Weight. Manufacturer programs that do not collect and recycle at least their minimum target by the end of the year must pay DEQ a penalty. The SCP has no penalties. For 2010 the Oregon performance target is set at 5.8 lbs./capita.

There are no set performance targets in the Washington program. If Ecology ultimately approves one or more independent plans then each plan will be responsible for its cumulative return share – a percentage target, not a pounds target. In the Washington system therefore there would be a floating performance target when there are independent plans – a target that would be converted to actual pounds only after the end of a program year.

Opinions on the value of performance targets were mixed, albeit with some thoughtful and insightful comments relating to the Oregon target setting process. Several stakeholders in the Oregon program noted that targets cause manufacturers to take their recycling responsibility seriously. Several others in the Oregon program noted the difficulty in establishing a target amount before there is any knowledge of how much can reasonably be collected.

Several stakeholders in both Oregon and Washington noted the “double edge sword” nature of performance targets – that once a target is reached before the end of the program year, the tendency is for manufacturers to slow down collection activity. As one Oregon program manager noted, “It’s nice to have a set target so you can plan for what you need to do….but there is also no incentive to collect more than your minimum. So the minimum becomes your maximum, although you are not allowed to shut down your network. Programs can do subtle things to discourage receiving new pounds once targets are reached or are in sight.”

4.3.7 Manufacturer Registration ProcessOne stakeholder volunteered that in other industry sectors it may be possible for the industry organization implementing the recycling program to register For example, nearly all manufacturers of rechargeable batteries fulfill their recycling requirements in the handful of mandatory states by entering into licensing agreements with the Rechargeable Battery Recycling Corporation (RBRC) and there are no manufacturer registration requirements with the state. Such an arrangement becomes more complicated when there are multiple compliance options available to manufacturers.


4.4 EconomicsBeyond the economic impact on processors/recyclers and collectors discussed above, several stakeholders provided observations about the economics of the first year of the E-Cycle programs.

First, several stakeholders noted that the state-wide systems both created program efficiencies and drove pricing for services lower. For example the WMMFA cited operating costs in 2009 as $0.24/lb. covering the cost of collection, transportation, recycling and program administration. This cost per pound is well below prices charged to scattered local governments and private programs before E-Cycle implementation, according to several local government officials. Some of this pricing reduction is likely due to increased program efficiencies (e.g., a consolidated administrative structure) and some due to the stronger pricing power that comes with larger, consolidated purchases of recycling and related services. Similarly, the Oregon State Contractor Program reported operating at approximately the same cost per pound as the WMMFA. Cost data for manufacturer programs in Oregon is not available.

Note that the cost per pound incurred by the WMMFA and the SCP are substantially less than the $0.39/lb. reimbursement rate practiced in the California electronics recycling system in which consumers are charged a visible recycling fee when purchasing a new television, monitor or laptop (note that desktops are not covered in the California program, a fact which would drive the price up slightly because of the positive recycling value of collected desktops). According to data submitted by the Consumer Electronics Association (CEA) to the Maine Department of Environmental Protection in November 2009 (see http://www.maine.gov/dep/rwm/publications/legislativereports/pdf/2010ewastereportfinal.pdf), average operational costs for recycling programs managed by electronics manufacturers in other states range from $0.18 - $0.30 per pound.

One stakeholder noted that this cost efficiency does come with a price – less local control over who managed covered electronics and where:

“These state programs don’t have a lot of flexibility for different situations in different communities. For example, if a community has invested in equipment that allows them to manage a material stream they should be allowed to continue doing that. For example, at the recycle center in Yakima all of their mixed paper goes across town to a pulper located only miles away. The local source is a viable option; it kept local jobs and made recycling mixed paper cheaper. Right now the state E-Cycle program does not have that flexibility.”

Finally, one manufacturer focused on the “internalized manufacturer fee” that finances these recycling programs. This manufacturer noted that because these are internalized fees the higher price of new products is invisible to the consumer, but that in effect this fee is subject to local and state sales taxes and retailers enjoy profit taking on the markup as well. Also, the absence of a visible fee for recycling is a missed opportunity for consumers to learn about the recycling program beyond program advertising and promotional efforts. This manufacturer concluded that “the end result of extended producer responsibility in Washington and Oregon is just a new revenue source for state and local governments to fund the collection of a new waste stream.”

The economics of producer managed systems and internalized recycling fees was not a major focus of this broader study and an analysis of the administrative and operating costs of these programs – and the economic effect of internalized manufacturer fees – should be studied further.

Total Reclaim is one of 10 processors participating in the Oregon and Washington E-Cycle Programs.


5.0 Summary of Findings The following preliminary findings concern the development and startup of the “E-Cycle” electronics recycling programs in Washington and Oregon. As noted in Section 1 this entire report and these findings were gathered from interviews of more than 30 stakeholders including electronics manufacturers, processors/recyclers, plan/program managers, garbage haulers, collectors, NGO representatives, refurbishment/reuse organizations, transporters, local and state governments. Note that members of the public that use the E-Cycle programs were not targeted in this study and were not interviewed.

5.1 Program Operations• Operational startup was smooth and collection amounts exceeded expectations. The operational start-up of the

E-Cycle programs was perceived as being remarkably smooth. Programs in both states are showing very high collection rates of covered electronics with Washington collecting 38.5 million pounds and Oregon collecting approximately 19 million pounds in 2009 or over 5 pounds per capita.

• Collection service is available in all cities with a population of 10,000 or more and in each county. The convenience requirement in both states appears to be effective for ensuring that collection service is available in each county and all cities with a population of 10,000 or more. There are now 240 collection sites in Washington and 30 in Oregon – a significant increase from pre-program collection activities. While these results clearly accomplish the 230 statutory objectives some manufacturers argued for more flexibility as practiced in other producer responsibility states such as Minnesota and Wisconsin.

• Processing capacity has increased in the Northwest. Two of the eight WMMFA processors/recyclers were established in Washington because of the new law, and one major processor/recycler established a facility in Portland because of the E-Cycle programs.

• The programmatic model of establishing a “default” stewardship program with an option for multiple manufacturer-run plans has proven to be viable to date. In Oregon this model has resulted in the “default” state-managed contractor program and three approved manufacturer-run programs. In Washington, all manufacturers opted in 2009 to participate in the “default” Standard Plan run by the manufacturer-managed WMMFA. For the 2010 program year, plans to operate two independent plans in Washington were submitted, but they were not approved by the Department of Ecology. Several stakeholders stated that the ability to create competition for the WMMFA was key – the assumption being that independent plans operating alongside the WMMFA’s Standard Plan would help keep costs competitive and the program efficient over the long term.

• Interviewees supported flexibility with regard to the collection of electronics. This was demonstrated by the variation in collection strategies implemented across programs. In both Oregon and Washington, some plans developed collection systems using existing networks of charitable organizations. Some Oregon plans employed widespread use of transfer stations operated by public entities and private solid waste companies. The Washington plan used a combination of private businesses, charitable organizations, and public sector locations. In both states there is widespread use of existing infrastructure.

• Some organizations that specialize in reusing and refurbishing electronic equipment for reuse have thrived under the new system while others have struggled. Those who have thrived have either continued, in one case, to refurbish old electronics and became qualified to provide service as a recycler/processor under the new system, or discontinued their refurbishment activities. Some stakeholders suggested making adjustments to the programs to allow some form of targeted or collective assistance to help refurbishers to qualify as limited recyclers (e.g., they only dismantle desktop computers) which could lead to more economically vibrant refurbishers – and could increase the repair and reuse of covered electronics. A more detailed analysis of the dynamics of reuse in electronics recycling programs beyond the Pacific Northwest would be helpful to confirm this conclusion as the analysis in this study is based on limited experiential data.

“Despite the efforts of the legislature, it comes down to doing the right thing and having people involved in the program be reasonable with each other.” (Anonymous stakeholder)


• Charitable thrift organizations are satisfied with the program. By serving as collectors for the E-Cycle programs, charitable thrift organizations are now getting paid to collect the equipment rather than often having to pay out of pocket to recycle donated broken equipment. In Washington there are 141 locations operated by charities, including 96 Goodwill sites and have become some of the most popular drop off sites. In Oregon charities have maintained their prominence as a dominant collector of used electronics in that state with more than 100 locations.

• Program education and promotion efforts need to be coordinated by a single entity. Program promotion and outreach is typically a cooperative effort across approved plans/programs, the state (using administrative fee proceeds) and local governments. When only a single plan/program exists it is easier to place more responsibility on that entity (e.g., the WMMFA) for overall system promotion and outreach. However, when multiple programs are approved as in Oregon, several stakeholders opined that in the interest of developing a coherent message to the public and to ensure a level playing field the regulatory agency should take the lead on system promotion and education.

5.2 Economics• The E-Cycle programs generated new jobs in Washington and Oregon. Based on interviews with processors/

recyclers there were approximately 140 net new jobs created across Washington and Oregon for program start-up: 79 in Washington and 61 in Oregon. Approximately 360 ongoing jobs at these facilities were reported attributable to the Washington and/or Oregon E-Cycle programs.

• The state-wide systems both created program efficiencies and drove pricing for services lower. The consolidation of electronics recycling activities into state-wide systems has created program efficiencies relative to the cost of collection, transportation and recycling before January 1, 2009. For example the WMMFA cited operating costs in 2009 as $0.24/lb and the Oregon SCP a similar rate – a cost well below prices charged to scattered local governments and private programs before E-Cycle implementation, according to several local government officials. Some of this pricing reduction is likely due to increased program efficiencies (e.g., a consolidated administrative structure) and some due to the stronger pricing power that comes with larger, consolidated purchases of recycling and related services.

• Cooperation and joint activities across states has created efficiencies. Officials in Washington and Oregon developed a joint E-Cycle name, logo and educational materials which saved money and provided a consistent message to consumers across states. This example of cross-state cooperation was possible because the programs are so similar operationally. Additional opportunities to develop cross-state efficiencies and avoid confusion in border communities may also exist.

• The long-term ability of service providers to thrive under a producer responsibility system is untested. Given the current economics of recycling electronics, recycling systems are a cost to be minimized – and theoretically the less collected and recycled the less costs to be incurred by manufacturers. Overall the short-term results are mixed: while some processors and other stakeholders expressed concern that the new system has resulted in a negative financial impact on processors, other processors with newly established facilities in the region expressed satisfaction with current arrangements.

• Managers of the “default” programs in both states expressed concern about the long-term sustainability of both programs under certain conditions. Concerns included impacts upon their programs if the following situations occurred:

1. state regulators allowed independent manufacturer programs to ignore requirements placed on them – especially if they were not required to have the same level of collection coverage;

2. the financing policy that uses both market share and return share could inadvertently cause manufacturers to leave the “default” program, potentially putting its viability at risk (e.g., in both states certain manufacturers with higher market shares than return shares would pay more than their return shares, and if they leave the default programs the costs to all manufacturers remaining in the default program would increase) and;


5.3 Environmental Impacts• Most covered electronics are now being managed in audited recycling channels rather than disposed in

landfills or managed in unaudited recycling channels. The consensus among most interviewed stakeholders was that the system provided greater accountability for the final destination of the covered electronics due to annual audits of direct recyclers/processors, recordkeeping requirements and review by state regulators. Prior to the E-Cycle programs, there was no mechanism to determine if computers, monitors and TVs were being handled in a manner protective of the environment and human health.

• Collection and recycling of covered electronics has increased. Washington collected 38.5 million pounds of electronics for recycling and Oregon collected approximately 19 million pounds in 2009.

• Approximately 5 million pounds of lead have been recycled as a result of the Washington and Oregon E-Cycles Program.

• More than 25,000 units have been reused in Oregon during the initial three quarters of the Oregon E-Cycles program. The Washington program allows collectors to resell or donate equipment for reuse, but does not track reuse activities.

5.4 Policy• Most stakeholders expressed support for the producer responsibility concept. This includes support from

several manufacturers although some manufacturers and plan/program managers took exception to specific elements in the approach used in Washington and Oregon specifically the prescriptive collection requirements. Some service providers questioned their own long-term sustainability in a system where global manufacturers finance and drive the system towards lower costs. Local governments in particular are very supportive of the E-Cycle programs.

• Allowing collectors to work for multiple plans is very popular among manufacturers. While manufacturers like this arrangement, questions about certain “shared collector” practices were raised by some government officials and plan/program managers. Manufacturers noted that the ability to share collectors was critical in meeting collection service requirements, particularly in more rural areas where the number of potential staffed collection sites is limited. Critics of collector sharing arrangements point to concerns about data reporting integrity, a reduced ability of programs to spot leakage (e.g., a change in product mix could be due to the collector sending some collected electronics to another plan/program), and the public benefit of more collection opportunities if collector sharing were restricted.

• Projecting a minimum number of pounds that each program must collect presents challenges and can create a disincentive to collect more than the target. In Oregon, after discussions and negotiations with manufacturers about a number of issues, DEQ established a minimum number of pounds of covered electronics that each program must collect that year of 3.3 lbs./capita. Actual collections for 2009 were recorded at 5.13 lbs./capita. Although establishing a lower, more achievable target does make it easier for all to meet the targets, it also creates a disincentive to collect more than the target. Further, it encourages a reduction in collections once the target is in sight. While DEQ required all programs to continue to provide collection service through all of 2009, it appears some programs may have undertaken efforts to reduce flows of covered electronics from their collectors, including encouraging shared collectors to send electronics to other programs. In Oregon, underperforming programs must pay a penalty for not collecting their minimum pounds. The Washington program establishes plan-specific percentages where under-performing plans pay over-performing plans. The Washington approach has yet to be tested as there was only one plan operating in Washington in 2009.

• Few stakeholders had comments about the overall financing mechanism in the respective programs. However, specific issues were raised, including support for the financing structure where the Washington Department of Ecology establishes individual manufacturer return share obligations but the WMMFA board is allowed to set financing policy for all WMMFA members.

• Stakeholders voiced little concern with manufacturer registration requirements. Registration with a state agency is a common requirement across many states with producer responsibility programs. In Washington and Oregon there is an administrative fee levied in conjunction with manufacturer registration and is based on a sliding scale based on the market share of all manufacturers of covered electronics. The only complaint raised about the manufacturer registration process related to the relatively high fees levied on manufacturers, particularly in Washington.


• Stakeholders had insightful comments about expanding the programs to include other products – and any new producer responsibility programs. One manufacturer said any new electronic products should be added to the existing system, while another manufacturer serving on the WMMFA board noted that “it is challenging to work on a system with two disparate product groups (TVs and computers) and if you added new products to the Authority [WMMFA] it could quickly become unwieldy…inherently having a manufacturer-run program is unsustainable across multiple states as the amount of management time, labor etc. required would be overwhelming.”

• A clear legal status and startup funding are both critical in any new program. As for the creation of any other similar system with WMMFA-type operational responsibilities, another WMMFA board member active at the programs creation strongly recommended that “the legal issues need to be resolved before the program is created – how the program is overseen and by whom, what is the legal status of entity. For example, what are you subject to as a private entity and/or as a public entity such as the state open meeting law?” Also there should be funding for start up operations included in any new such program for other products.


Appendix 1 - Active Oregon Collection Locations

Approximately 230 total

Note: an “X” means the program has a direct arrangement with the collector while an “O” means the collector provides service to that program via program-to-program arrangements

DELL IPR MRM SCP COUNTY Facility Name

X HARNEY 4R RECYCLING – HINES

X GRANT 4R RECYCLING - PRAIRIE CITY

X CLACKAMAS ACE COMPUTER REPAIR

X LINN ALBANY-LEBANON RECYCLING & TRANSFER STATION

X X JACKSON ALLIED ENVIRONMENTAL SVCS. LLC

X BENTON ALLIED WASTE - COFFIN BUTTE LANDFILL

X BENTON ALLIED WASTE – CORVALLIS

X JOSEPHINE ALLIED WASTE - MERLIN TRANSFER STATION

X MARION ALLIED WASTE – WOODBURN

O O X X WALLOWA ANT FLAT LANDFILL

O X X X BAKER BAKER SANITARY SERVICE

X KLAMATH BEATTY TRANSFER STATION

O O X COOS BEAVER HILL DISPOSAL SITE

X MARION BITS & PCS COMPUTERS INC.

X YAMHILL BITS & PCS COMPUTERS INC.

X KLAMATH BLY TRANSFER STATION

X KLAMATH BONANZA TRANSFER STATION

X X CURRY BROOKINGS TRANSFER STATION

X HARNEY C&B TRANSFER STATION

X WASHINGTON C&M RECYCLERS

X X X CLACKAMAS CANBY DISPOSAL & TRANSFER STATION

O X X TILLAMOOK CART’M RECYCLING

X KLAMATH CHEMULT LANDFILL

X KLAMATH CHILOQUIN TRANSFER STATION

X UNION CITY GARBAGE SERVICE

X MULTNOMAH CITY RECYCLE

X X X COLUMBIA COLUMBIA COUNTY TRANSFER STATION

X GILLIAM COLUMBIA RIDGE LANDFILL

O X X X WASHINGTON COMPUTER DRIVE CONNECTION

X JACKSON COMPUTER DROP OFF

O X CURRY COMPUTER FUSION

X BENTON COMPUTER TUNE UP & REPAIR


DELL IPR MRM SCP COUNTY Facility NameO X GILLIAM CONDON TRANSFER STATION

X LANE COTTAGE GROVE TRANSFER STATION

X KLAMATH CRESCENT TRANSFER STATION

X CROOK CROOK COUNTY LANDFILL

X CLACKAMAS CRT PROCESSING

X X CURRY CURRY TRANSFER & RECYCLING PORT ORFORD TRANSFER STATION

O X X DESCHUTES DESCHUTES RECYCLING AT KNOTT LANDFILL

X TILLAMOOK DON G. AVERILL RECYCLING

X X WASHINGTON EARTH PROTECTION SERVICES, INC.

X X JACKSON ECS REGENESYS

X X WASHINGTON FAR WEST FIBERS - BEAVERTON

X X CLACKAMAS FAR WEST FIBERS - FOOTHILLS RD

X X MULTNOMAH FAR WEST FIBERS - NE MARX ST

X X MULTNOMAH FAR WEST FIBERS - NW QUIMBY

X X MULTNOMAH FAR WEST FIBERS - ROSA PARKS WAY

X X MULTNOMAH FAR WEST FIBERS - SE 17TH

X X WASHINGTON FAR WEST FIBERS - SE ALEXANDER

X LANE FLORENCE TRANSFER STATION

X X WASHINGTON FOREST GROVE TRANSFER STATION

X O WHEELER FOSSIL SOLID WASTE TRANSFER & RECYCLING

X MULTNOMAH FREE GEEK

X KLAMATH FT. KLAMATH TRANSFER STATION

X X X MARION/POLK GARTEN NORTH

O X X POLK GARTEN SERVICES - DALLAS

X X LANE GARTEN SERVICES - EUGENE

X X MARION/POLK GARTEN SERVICES, INC.

X X MARION GARTEN SOUTH

X X LANE GLENWOOD CENTRAL RECEIVING STATION

X UMATILLA GOOD SHEPHERD HEALTHCARE HERMISTON

X LANE GOODWILL - 29TH & PORTLAND DONATION CENTER

X X MULTNOMAH GOODWILL - 57TH & NE FREMONT

X X WASHINGTON GOODWILL - AIRPORT MARKETPLACE

X O X LINN GOODWILL - ALBANY

X O JACKSON GOODWILL - ASHLAND RETAIL CENTER

X X MULTNOMAH GOODWILL - BARBUR BLVD DONATION EXPRESS

X X WASHINGTON GOODWILL - BASELINE STORE

X X WASHINGTON GOODWILL - BEAVERTON

X X WASHINGTON GOODWILL - BEAVERTON MILL END STORE

X X DESCHUTES GOODWILL - BEND

X X MULTNOMAH GOODWILL - BROADWAY EAST STORE

X X WASHINGTON GOODWILL - BRONSON CREEK DONATION EXPRESS


DELL IPR MRM SCP COUNTY Facility NameX X CLACKAMAS GOODWILL - CANBY SQUARE DONATION EXPRESS

X X MULTNOMAH GOODWILL - CANYON RD DONATION EXPRESS

X X POLK GOODWILL - CENTRAL PLAZA SHOPPING CENTER

X O JACKSON GOODWILL - CENTRAL POINT RETAIL

X X CLACKAMAS GOODWILL - CLACKAMAS STORE

X O LANE GOODWILL - COBURG DONATION CENTER

X X WASHINGTON GOODWILL - CORNELL RD

X X BENTON GOODWILL - CORVALLIS STORE

X O LANE GOODWILL - COTTAGE GROVE

X X POLK GOODWILL - DALLAS

X X CLACKAMAS GOODWILL - DAMASCUS SQUARE DONATION EXPRESS

X X MULTNOMAH GOODWILL - DIVISION & 143RD DONATION EXPRESS

X O JACKSON GOODWILL - DOWNTOWN MEDFORD DONATION CENTER

X X CLACKAMAS GOODWILL - ESTACADA

X X WASHINGTON GOODWILL - FARMINGTON CENTER DONATION EXPRESS

X X WASHINGTON GOODWILL - FOREST GROVE

X X MULTNOMAH GOODWILL - GLISAN DONATION EXPRESS

X O JOSEPHINE GOODWILL - GRANTS PASS

X LANE GOODWILL - GREEN ACRES STORE

X MULTNOMAH GOODWILL - GRESHAM GROCERY OUTLET

X X MULTNOMAH GOODWILL - GRESHAM STORE

X X WASHINGTON GOODWILL - HALL BLVD DONATION EXPRESS

X X WASHINGTON GOODWILL - HART RD DONATION EXPRESS

X X WASHINGTON GOODWILL - HILLSBORO

X X MULTNOMAH GOODWILL - HOLGATE & 82ND

X X HOOD RIVER GOODWILL - HOOD RIVER

X LANE GOODWILL - JUNCTION CITY

X X MARION GOODWILL - KEIZER

X KLAMATH GOODWILL - KLAMATH FALLS

X X WASHINGTON GOODWILL - KMART SHOPPING CENTER

X X CLACKAMAS GOODWILL - LAKE OSWEGO DONATION EXPRESS

X O X MULTNOMAH GOODWILL - LAMB’S THRIFTWAY/TROUTDALE PLAZA

X X MARION GOODWILL - LANCASTER & DURBIN

X O X LINN GOODWILL - LEBANON SHOP’N’KART DRIVE AWAY

X X LINCOLN GOODWILL - LINCOLN CITY

X X MULTNOMAH GOODWILL - LOMBARD STORE

X X WASHINGTON GOODWILL - MARKET CENTRE ALOHA

X X YAMHILL GOODWILL - MCMINNVILLE STORE


DELL IPR MRM SCP COUNTY Facility NameX X MULTNOMAH GOODWILL - MEADOWLANDS DONATION EXPRESS

X X CLACKAMAS GOODWILL - MOLALLA BI-MART

X X MULTNOMAH GOODWILL - NE SANDY DONATION EXPRESS

X O X YAMHILL GOODWILL - NEWBERG EXTREME CYCLE

X X DESCHUTES GOODWILL - NEWPORT AVENUE MARKET DRIVE AWAY

X O X LINCOLN GOODWILL - NEWPORT BIG GUYS DRIVE AWAY

X O COOS GOODWILL - NORTH BEND

X O X CLACKAMAS GOODWILL - OAK GROVE

X X CLACKAMAS GOODWILL - OREGON CITY STORE

X LANE GOODWILL - PIONEER PARKWAY

X X CLACKAMAS GOODWILL - PORTLAND OUTLET

X X MULTNOMAH GOODWILL - PORTLAND STORE

X X MULTNOMAH GOODWILL - POWELL STORE

X X DESCHUTES GOODWILL - REDMOND

X X DESCHUTES GOODWILL - REDMOND GROCERY OUTLET

X O LANE GOODWILL - RIVER RD

X O DOUGLAS GOODWILL - ROSEBURG SERVICE OFFICE

X X POLK GOODWILL - SALEM OUTLET

X X MARION GOODWILL - SALEM STORE

X X MULTNOMAH GOODWILL - SAN RAFAEL STORE

X X CLACKAMAS GOODWILL - SANDY STORE

X X COLUMBIA GOODWILL - SCAPPOOSE HIGH SCHOOL PHARMACY

X X MULTNOMAH GOODWILL - SELLWOOD DONATION EXPRESS

X O LANE GOODWILL - SENECA

X X DESCHUTES GOODWILL - SENTRY MARKET DRIVE

X X MULTNOMAH GOODWILL - SHATTUCK RD RITE AID

X X WASHINGTON GOODWILL - SHERWOOD PLAZA

X X MARION GOODWILL - SILVERTON

X X MARION GOODWILL - SOUTH SALEM STORE

X X POLK GOODWILL - SOUTH SALEM WAL-MART DRIVE AWAY

X O LANE GOODWILL - SPRINGFIELD

X X MULTNOMAH GOODWILL - ST. GABRIELS BETHANY/NW PORTLAND

X MULTNOMAH GOODWILL - ST. JOHN’S

X X MARION GOODWILL - STAYTON BIMART

X X CLACKAMAS GOODWILL - SUNNYSIDE DONATION EXPRESS

X X BENTON GOODWILL - SUNSET SHOPPING CENTER BI-MART

X X DESCHUTES GOODWILL - TARGET STORE DRIVE AWAY

X LANE GOODWILL - THURSTON

X X WASHINGTON GOODWILL - TIGARD



X X WASHINGTON GOODWILL - TIGARD PACIFIC HWY DONATION EXPRESS

X X MULTNOMAH GOODWILL - W BURNSIDE STORE

X X POLK GOODWILL - WALLACE ROAD

X X CLATSOP GOODWILL - WARRENTON FRED MEYER

X X CLACKAMAS GOODWILL - WEBSTER RD DONATION EXPRESS

X LANE GOODWILL - WEST EUGENE

X X MARION GOODWILL - WEST SALEM DONATION EXPRESS

X X WASHINGTON GOODWILL - WESTSIDE OUTLET HILLSBORO

X X CLACKAMAS GOODWILL - WILSONVILLE TOWN CENTER

O X MULTNOMAH GOODWILL - WOOD VILLAGE/CHERRY PARK MARKET

X X MARION GOODWILL - WOODBURN

X X MULTNOMAH GOODWILL - WOODSTOCK

X X MULTNOMAH GRESHAM SANITARY SERVICE BIRDSDALE COLLECTION SITE

O O X UNION HABITAT FOR HUMANITY RESTORE

X X WASHINGTON HILLSBORO LANDFILL

X CLACKAMAS HOMETOWN COMPUTERS

O X X HOOD RIVER HOOD RIVER RECYCLING AND TRANSFER STN

X CLACKAMAS ICI COMPUTERS

X X X CLACKAMAS KB RECYCLING - CLACKAMAS MRF

X MARION KEIZER COMPUTER ANNEX

X KLAMATH KENO TRANSFER STATION

X X KLAMATH KLAMATH COUNTY SOLID WASTE LANDFILL

X KLAMATH KLAMATH REGIONAL DISPOSAL TRANSFER STATION

O X LAKE LAKE COUNTY DISPOSAL

X KLAMATH LANGELL VALLEY TRANSFER STATION

X YAMHILL LEWIS AUDIO VIDEO

O X X LINCOLN LINCOLN COUNTY RECYCLING CENTER

O X X JEFFERSON MADRAS SANITARY SERVICE

X KLAMATH MALIN TRANSFER STATION

X KLAMATH MERRILL TRANSFER STATION

X MULTNOMAH METRO CENTRAL TRANSFER STATION

X CLACKAMAS METRO SOUTH TRANSFER STATION

X JACKSON MULTINET INFORMATION SYSTEMS

O X X DESCHUTES NEGUS TRANSFER STATION

X X CURRY NESIKA BEACH TRANSFER STATION

O X DOUGLAS NEXT GENERATION RECYCLE

X X X LANE NEXTSTEP RECYCLING - EUGENE

X X X LANE NEXTSTEP RECYCLING - SPRINGFIELD

X X X LINCOLN NORTH LINCOLN SANITARY

X X MARION NORTH MARION COUNTY TRANSFER STATION


DELL IPR MRM SCP COUNTY Facility NameO X MORROW NORTH MORROW COUNTY TRANSFER STATION

X KLAMATH ODESSA TRANSFER STATION

O O X X MALHEUR ONTARIO TRANSFER STATION

X MULTNOMAH PACIFIC LAND & CLEARING

X CLACKAMAS PACIFIC LAND CLEARING & RECYCLING

X CLACKAMAS PC PIECES

O O X X UMATILLA PENDLETON SANITARY SERVICE TRANSFER STATION

X X JACKSON PERSONAL COMPUTER TECHNOLOGIES

X X WASHINGTON PRIDE RECYCLING

X JACKSON RESTORE HABITAT FOR HUMANITY

X YAMHILL RIVERBEND LANDFILL CO.

X CLACKAMAS RS DAVIS RECYCLING

X UMATILLA RS DAVIS RECYCLING INC.

X X MARION SALEM KEIZER TRANSFER STATION

X CLACKAMAS SANDY TRANSFER STATION

O X UMATILLA SANITARY DISPOSAL TRANSFER STATION

X X SHERMAN SHERMAN COUNTY TRANSFER STATION

X DOUGLAS SHOP & SAVE

O X MORROW SOUTH TRANSFER STATON

X O X JOSEPHINE SOUTHERN OREGON SANITATION

X KLAMATH SPRAGUE RIVER TRANSFER STATION

O X CROOK ST. VINCENT DE PAUL RESALE STORE

X MULTNOMAH STANDARD TV & APPLIANCE

X MULTNOMAH STANDARD TV & APPLIANCE

X WASHINGTON STANDARD TV & APPLIANCE

X DOUGLAS SUNRISE ENTERPRISE - GREEN DISTRICT COLLECTION CENTER

X DOUGLAS SUNRISE ENTERPRISES - MULHOLLAND DRIVE

X DOUGLAS SUNRISE ENTERPRISES - SHOP & SAVE

X LINN SWEET HOME TRANSFER STATION

X JACKSON TAUL CORPORATION

O O X X WASCO THE DALLES TRANSFER STATION

X X MULTNOMAH TOTAL RECLAIM, INC.

X UMATILLA TRIBAL ENVIRONMENTAL RECOVERY FACILITY (TERF)

X X JACKSON VALLEY VIEW TRANSFER STATION



X WASHINGTON VALUE VILLAGE

X LANE VENETA TRANSFER STATION

X LANE VIDA TRANSFER STATION

X COOS WEST COAST RECYCLING & TRANSFER

O X CLACKAMAS WILLAMETTE RESOURCES INC.

X X CURRY WRIDGE CREEK TRANSFER STATION


Appendix 2 - Active Washington Collection Locations

(As of July, 2009 - Approx 240 total)

Collector Site Name Organization EPR Number County Effective

Date

Experience Merchandise Thrift Store Adams County Developmental Disabilities EPR00547 Adams 1/27/2009

CEP Recycle Asotin Co. HHH EPR00471 Asotin 11/17/2008

Clayton-Ward Company Kennewick Clayton-Ward Company EPR00526 Benton 12/12/2008

Clayton-Ward Company Richland Clayton-Ward Company EPR00526 Benton 12/12/2008

Horn Rapids Sanitary Landfill City of Richland - Landfill EPR00490 Benton 11/14/2008

Packs Auction Service Packs Auction Service EPR00545 Benton 12/31/2008

Stay Tan West Stay Tan West EPR00542 Benton 12/30/2008

City of Chelan Recycle Center City of Chelan EPR00514 Chelan 12/9/2008

Salvation Army Wenatchee The Salvation Army Seattle DHQ EPR00470 Chelan 9/18/2008

EcycleNW EcycleNW EPR00262 Clallam 8/22/2008

Goodwill Port Angeles Store Tacoma Goodwill EPR00290 Clallam 10/24/2008

AER Vancouver/Portland AER Corp EPR00376 Clark 8/22/2008

Goodwill - 205 and Mill Plain Donation Center

Columbia Willamette Goodwill EPR00343 Clark 9/18/2008

Goodwill - Fourth Plain at 140th Donation Center


Goodwill - Main and Fourth Plain Donation Center


Goodwill Battleground Store Columbia Willamette Goodwill EPR00343 Clark 9/18/2008

Goodwill Cascade Park Donation Center


Goodwill Fishers Landing Store Columbia Willamette Goodwill EPR00343 Clark 9/18/2008

Goodwill Hazel Dell Store Columbia Willamette Goodwill EPR00343 Clark 9/18/2008

Goodwill Orchards Donation Center


Goodwill Salmon Creek Donation Center


Goodwill Salmon Creek Store Columbia Willamette Goodwill EPR00343 Clark 1/16/2009

Goodwill SE Vancouver Donation Center


Goodwill Vancouver Outlet Columbia Willamette Goodwill EPR00343 Clark 9/18/2008

Goodwill Vancouver Store Columbia Willamette Goodwill EPR00343 Clark 9/18/2008



DateGoodwill Washougal Donation Center


IMS Electronics Recycling IMS Electronics Recycling EPR00311 Clark 9/2/2008

Washougal Facility PSC Environmental Services EPR00312 Clark 11/21/2008

CEP Recycle Columbia Co. HHH EPR00471 Columbia 11/18/2008

Cowlitz County Habitat for Humanity ReStore

Cowlitz County Habitat for Humanity EPR00592 Cowlitz 7/10/2009

Goodwill Longview Store Tacoma Goodwill EPR00290 Cowlitz 10/24/2008

Waste Control Recycling Waste Control Recycling EPR00443 Cowlitz 9/18/2008

Goodwill East Wenatchee Store Inland Northwest Goodwill EPR00334 Douglas 8/22/2008

Inchelium Community Center Colville Confederated Tribes EPR00578 Ferry 4/9/2009

Keller Community Center Colville Confederated Tribes EPR00578 Ferry 4/9/2009

Torboy Transfer Station Ferry County Waste Management EPR00487 Ferry 12/29/2008

Tommy’s Steel & Salvage Tommy’s Steel & Salvage EPR00519 Franklin 12/8/2009

CEP Recycle Garfield Co. HHH EPR00471 Garfield 12/16/2008

CDSI Transfer & Recycle Consolidated Disposal Service, Inc. EPR00279 Grant 8/22/2008

Consolidated Disposal Service Consolidated Disposal Service, Inc. EPR00279 Grant 8/22/2008

GCD Seniors Grand Coulee Dam Area Seniors, Inc EPR00330 Grant 7/7/2008

Goodwill Moses Lake Store Inland Northwest Goodwill EPR00334 Grant 8/22/2008

Salvation Army Aberdeen The Salvation Army Seattle DHQ EPR00470 Grays Harbor 9/18/2008

Waste Connections Inc dba Aberdeen Sanitation

Waste Connections Inc dba Aberdeen Sanit EPR00522 Grays Harbor 12/11/2008

Camano Island Transfer Station & Recycle Park

Island County Public Works SW Division EPR00530 Island 12/15/2008

Island Recycling Island Recycling EPR00517 Island 12/3/2008

Oak Harbor Drop Box Station Island County Public Works SW Division EPR00530 Island 12/15/2008

Goodwill Port Townsend Store Tacoma Goodwill EPR00290 Jefferson 10/24/2008

Public Recycling Center - Pacific Commercial Metal Recycling EPR00583 King 4/28/2009

3R Technology 3R Technology EPR00370 King 8/8/2008

A Plus Removal and Recycle A Plus Removal & Recycle EPR00491 King 11/13/2008

American Electronics Recycling - Kent AER Corp EPR00376 King 8/22/2008

American Electronics Recycling Corp - Tukwila AER Corp EPR00376 King 1/7/2009

AtWork! Issaquah Recycling Center AtWork! EPR00540 King 12/29/2008

Busby Junk Removal Busby Junk Removal, LLC EPR00466 King 9/18/2008

Computer Recycling Service Computer Recycling Service, Inc. EPR00377 King 8/22/2008

Deseret Industries - Federal Way Deseret Industries EPR00546 King 2/11/2009

Deseret Industries - Shoreline Deseret Industries EPR00546 King 2/11/2009



DateEC Computer EC Computer EPR00531 King 12/16/2008

EcoLights Northwest Total Reclaim, Inc. EPR00544 King 12/30/2008

EWC Group, Inc EWC Group, Inc EPR00472 King 1/20/2009

George Electronix George Electronix EPR00549 King 1/13/2009

Goods for the Planet Goods for the Planet, Inc. EPR00386 King 12/12/2008

Goodwill Auburn Store Tacoma Goodwill EPR00290 King 10/24/2008

Goodwill Ballard Store Seattle Goodwill EPR00310 King 9/18/2008

Goodwill Bellevue P&R Donation Center Seattle Goodwill EPR00310 King 9/18/2008

Goodwill Burien Store Seattle Goodwill EPR00310 King 9/18/2008

Goodwill Federal Way Store Tacoma Goodwill EPR00290 King 10/24/2008

Goodwill Kent Store Tacoma Goodwill EPR00290 King 10/24/2008

Goodwill Kingsgate Donation Center Seattle Goodwill EPR00310 King 12/18/2008

Goodwill Maple Valley Store Tacoma Goodwill EPR00290 King 10/24/2008

Goodwill Newport Hills Donation Center Seattle Goodwill EPR00310 King 9/18/2008

Goodwill Renton Store Seattle Goodwill EPR00310 King 9/18/2008

Goodwill Sammamish Donation Center Seattle Goodwill EPR00310 King 12/18/2008

Goodwill Seattle Store Seattle Goodwill EPR00310 King 9/18/2008

Goodwill Shoreline Store Seattle Goodwill EPR00310 King 9/18/2008

Goodwill Southcenter Store Seattle Goodwill EPR00310 King 9/18/2008

Goodwill Totem Lake Donation Center Seattle Goodwill EPR00310 King 9/18/2008

Goodwill Woodinville P&R Donation Center Seattle Goodwill EPR00310 King 9/18/2008

Happy Hauler LLC Happy Hauler LLC EPR00479 King 1/7/2009

InterConnection Computer Reuse and Learning Center

InterConnection Computer Reuse EPR00369 King 9/8/2008

Mitronics Mitronics EPR00559 King 1/28/2009

PC Recycle - Bellevue PC Recycle EPR00365 King 9/11/2008

PC Recycle - Federal Way PC Recycle EPR00365 King 9/11/2008

PSC - Georgetown PSC Environmental Services EPR00312 King 11/5/2008

RE-PC Seattle RE-PC EPR00426 King 9/12/2008

RE-PC Tukwila RE-PC EPR00426 King 9/12/2008

Salvation Army Burien Store The Salvation Army Seattle ARC EPR00543 King 12/30/2008

Salvation Army Covington Donation Site

The Salvation Army Seattle ARC EPR00543 King 12/30/2008

Salvation Army Midway Thrift Store


Salvation Army Redmond Donation Site


Salvation Army Renton Thrift Store




Date

Salvation Army Seattle ARC The Salvation Army Seattle ARC EPR00543 King 12/30/2008

Santamaria and Sons Ravensdale Santamaria and Sons, Inc EPR00314 King 9/18/2008

SB Foundation SB Foundation EPR00573 King 4/2/2009

St Vincent de Paul 1st Ave S St Vincent de Paul Seattle/King County EPR00525 King 12/31/2008

St Vincent de Paul 4th Ave S St Vincent de Paul Seattle/King County EPR00525 King 1/10/2009

St Vincent de Paul Aurora Ave N St Vincent de Paul Seattle/King County EPR00525 King 12/31/2008

St Vincent de Paul Bothell Way NE

St Vincent de Paul Seattle/King County EPR00525 King 12/31/2008

St Vincent de Paul Sunset Blvd NE

St Vincent de Paul Seattle/King County EPR00525 King 12/31/2008

State Surplus Auburn Site Dept of General Administration / Surplus EPR00480 King 12/11/2008

Total Reclaim 6th Ave Site Total Reclaim, Inc. EPR00544 King 12/30/2008

Waste Management South King County

Waste Management of Washington EPR00264 King 2/12/2009

BI TRANSFER STATION Bainbridge Disposal EPR00374 Kitsap 12/31/2008

Bremerton St. Vincent dePaul St Vincent de Paul Bremerton EPR00494 Kitsap 11/19/2008

Goodwill Bainbridge Island Don. Center Seattle Goodwill EPR00310 Kitsap 12/12/2008

Goodwill Bremerton Store Seattle Goodwill EPR00310 Kitsap 9/18/2008

Goodwill Port Orchard Store Seattle Goodwill EPR00310 Kitsap 9/18/2008

Olympic View Transfer Station Waste Management of Washington EPR00264 Kitsap 1/12/2009

Peninsula All Shred All Shred EPR00502 Kitsap 11/24/2008

Recycle Earth Inc Recycle Earth EPR00550 Kitsap 2/1/2009

Cle Elem Trading Post Cle Elem Trading Post EPR00527 Kittitas 12/30/2008

Goodwill Ellensburg Store Tacoma Goodwill EPR00290 Kittitas 10/24/2008

Kittitas Valley Recycling Kittitas Valley Recycling EPR00515 Kittitas 12/3/2008

Regional Disposal Company - Goldendale Transfer Regional Disposal Company EPR00482 Klickitat 10/29/2008

Goodwill Centralia Store Tacoma Goodwill EPR00290 Lewis 10/24/2008

Lincoln County Transfer Station Lincoln County Transfer Station EPR00367 Lincoln 9/8/2008

Goodwill Roosters Family Restuarant Donation Stati Tacoma Goodwill EPR00290 Mason 10/27/2008

Wilson Recycling LLC Wilson Recycling LLC EPR00513 Mason 12/9/2008

Green Okanagon Recycle Green Okanagon Recycle EPR00572 Okanogan 4/13/2009

Methow Recycle Methow Recycles EPR00298 Okanogan 11/17/2008

Nespelem Community Center Colville Confederated Tribes EPR00578 Okanogan 4/9/2009

Omak Community Center Colville Confederated Tribes EPR00578 Okanogan

Pacific Solid Waste Disposal Pacific Solid Waste Disposal Inc EPR00371 Pacific 9/11/2008



Date

Royal Heights Transfer Station Royal Heights Transfer Station EPR00488 Pacific 11/5/2008

Deer Valley Transfer Station Pend Oreille Co Public Works EPR00404 Pend Oreille 10/3/2008

Better PC Recycle LLC Better PC Recycle LLC EPR00509 Pierce 5/15/2009

Ft Lewis Recycle Center LeMay Inc EPR00529 Pierce 12/26/2008

Goodwill 38 Street Donation Station Tacoma Goodwill EPR00290 Pierce 10/24/2008

Goodwill 6th Ave Plaza Store Tacoma Goodwill EPR00290 Pierce 12/5/2008

Goodwill 72 Street Store Tacoma Goodwill EPR00290 Pierce 10/24/2008

Goodwill Bonney Lake Wal-Mart Donation Station Tacoma Goodwill EPR00290 Pierce 12/5/2008

Goodwill Chevron Mini Mart Donation Station Tacoma Goodwill EPR00290 Pierce 10/24/2008

Goodwill Dollar Tree Donation Station Tacoma Goodwill EPR00290 Pierce 12/5/2008

Goodwill Gig Harbor Store Tacoma Goodwill EPR00290 Pierce 10/24/2008

Goodwill Key Peninsula Mkt Donation Station Tacoma Goodwill EPR00290 Pierce 10/24/2008

Goodwill Lakewood Store Tacoma Goodwill EPR00290 Pierce 10/24/2008

Goodwill Meridian WalMart Tacoma Goodwill EPR00290 Pierce 1/13/2009

Goodwill Orting Eagles Lodge Donation Station Tacoma Goodwill EPR00290 Pierce 10/27/2008

Goodwill Puyallup K Mart Store Tacoma Goodwill EPR00290 Pierce 10/24/2008

Goodwill Qwik Mart Donation Station Tacoma Goodwill EPR00290 Pierce 10/27/2008

Goodwill Rite Aid 176th Donation Station Tacoma Goodwill EPR00290 Pierce 12/5/2008

Goodwill Roses IGA Donation Station Tacoma Goodwill EPR00290 Pierce 10/27/2008

Goodwill South Hill Store Tacoma Goodwill EPR00290 Pierce 10/27/2008

Goodwill Spanaway Store Tacoma Goodwill EPR00290 Pierce 10/27/2008

Goodwill TACID Donation Station Tacoma Goodwill EPR00290 Pierce 10/27/2008

Goodwill Tacoma Landfill & Recycle Donation Statio Tacoma Goodwill EPR00290 Pierce 10/27/2008

Goodwill Tacoma Outlet Store Tacoma Goodwill EPR00290 Pierce 12/5/2008

Goodwill Top Foods Donation Station Tacoma Goodwill EPR00290 Pierce 12/5/2008

Green PC Green PC EPR00520 Pierce 7/8/2009

McChord Recycling Center McChord Air Force Base EPR00421 Pierce 12/9/2008

MONARCH ASSOCIATION Monarch Association EPR00535 Pierce 12/26/2008

Oakland Radio and Tv Oakland Radio and TV Inc EPR00418 Pierce 9/11/2008

PC Computers PC Computers EPR00581 Pierce 5/4/2009

Public Recycling Center - Canyon Rd Commercial Metal Recycling EPR00583 Pierce 4/28/2009



DateSalvation Army Bonney Lake Donation Site

The Salvation Army Seattle ARC EPR00543 Pierce 12/30/2008

Salvation Army Puyallup Donation Site


Salvation Army Puyallup Thrift Store


SBK Storage Recycling SBK Storage EPR00564 Pierce 3/20/2009

St. Vincent de Paul S. 56th St. St Vincent de Paul Tacoma EPR00561 Pierce 2/13/2009

St. Vincent de Paul South Hill Meridian Ave E. St Vincent de Paul Tacoma EPR00561 Pierce 2/13/2009

Tacoma Recycling Co Tacoma Recycling Co., Inc. EPR00477 Pierce 12/4/2008

Consignment Treasures LLC Consignment Treasures LLC EPR00489 San Juan 11/7/2008

The Exchange Orcas Recycling Services EPR00512 San Juan 3/18/2009

Aktion Club of Anacortes Aktion Club of Anacortes EPR00523 Skagit 12/19/2008

Appliance Connection Jaco Environmental EPR00486 Skagit 3/20/2009

Goodwill Mount Vernon Store Seattle Goodwill EPR00310 Skagit 9/18/2008

Salvation Army Mt Vernon Thrift Store

The Salvation Army Seattle ARC EPR00543 Skagit 12/30/2008

Sedro-Woolley City Recycling Facility City of Sedro-Woolley EPR00324 Skagit 8/22/2008

Underwood Transfer Facility Skamania County Solid Waste Division EPR00358 Skamania 9/8/2008

Ace Metal Company and Mukilteo Recycling Center Ace Metal Company EPR00557 Snohomish 2/20/2009

Appliance Recycling Outlet Jaco Environmental EPR00486 Snohomish 11/14/2008

E-Waste, LLC E-Waste LLC EPR00446 Snohomish

Goodwill Lynnwood Store Seattle Goodwill EPR00310 Snohomish 9/18/2008

Goodwill Marysville Seattle Goodwill EPR00310 Snohomish 9/18/2008

Goodwill Mill Creek Donation Center Seattle Goodwill EPR00310 Snohomish 9/18/2008

Goodwill Monroe Donation Center Seattle Goodwill EPR00310 Snohomish 9/18/2008

Goodwill South Everett Store Seattle Goodwill EPR00310 Snohomish 9/18/2008

Kolb Enterprize Kolb Enterprize EPR00590 Snohomish 6/19/2009

PC Recycle - Lynnwood PC Recycle EPR00365 Snohomish 9/11/2008

PC Recycle - Marysville PC Recycle EPR00365 Snohomish 9/11/2008

PC Recycle - Woodinville PC Recycle EPR00365 Snohomish 9/11/2008

Rubatino Refuse Removal RUBATINO REFUSE REMOVAL INC EPR00368 Snohomish 1/10/2009

Salvation Army Lynnwood Donation Center

The Salvation Army Seattle ARC EPR00543 Snohomish 12/30/2008

Salvation Army Snohomish Donation Center

The Salvation Army Seattle ARC EPR00543 Snohomish 12/30/2008

Smokey Point Recycling Smokey Point Recycling EPR00591 Snohomish 6/15/2009

St Vincent dePaul Lynnwood St Vincent de Paul Northsound EPR00560 Snohomish 1/28/2009



Date

St. Vincent dePaul Everett St Vincent de Paul Northsound EPR00560 Snohomish 1/28/2009

St. Vincent dePaul Monroe St Vincent de Paul Northsound EPR00560 Snohomish 1/28/2009

TK Enterprise TK Enterprise EPR00516 Snohomish 12/3/2008

Truck On Call Truck On Call EPR00528 Snohomish 12/19/2008

Earthworks Recycling, Inc. Earthworks Recycling, Inc. EPR00305 Spokane 1/13/2009

Goodwill Cheney Donation Center Inland Northwest Goodwill EPR00334 Spokane 8/22/2008

Goodwill Downtown Spokane Plant/Dock Donation Cent Inland Northwest Goodwill EPR00334 Spokane 8/22/2008

Goodwill North Division Y Donation Center Inland Northwest Goodwill EPR00334 Spokane 8/22/2008

Goodwill North Nevada Store Inland Northwest Goodwill EPR00334 Spokane 8/22/2008

Goodwill NW Spokane Donation Center Inland Northwest Goodwill EPR00334 Spokane 8/22/2008

Goodwill Palouse Hwy Donation Center Inland Northwest Goodwill EPR00334 Spokane 8/22/2008

Goodwill South Spokane Donation Center Inland Northwest Goodwill EPR00334 Spokane 8/22/2008

Goodwill Spokane Valley Store Inland Northwest Goodwill EPR00334 Spokane 8/22/2008

Goodwill Spokane Vlly Argonne Donation Center Inland Northwest Goodwill EPR00334 Spokane 8/22/2008

Goodwill Spokane Vlly Dishman-Mica Donation Center Inland Northwest Goodwill EPR00334 Spokane 8/22/2008

Goodwill Spokane Warehouse Inland Northwest Goodwill EPR00334 Spokane 12/10/2008

Goodwill Wandermere Donation Center Inland Northwest Goodwill EPR00334 Spokane 8/22/2008

Inland ReTech Electronic Recycling, LLC dba Inland ReT EPR00335 Spokane 12/12/2008

Jaco Environmental Jaco Environmental EPR00486 Spokane 3/26/2009

Recycle Techs Recycle Techs EPR00478 Spokane 10/8/2008

Salvation Army Spokane The Salvation Army Seattle DHQ EPR00470 Spokane 9/18/2008

Salvation Army Spokane Valley The Salvation Army Seattle DHQ EPR00470 Spokane 9/18/2008

Goodwill Colville Store Inland Northwest Goodwill EPR00334 Stevens 8/22/2008

Goodwill Lacey Store Tacoma Goodwill EPR00290 Thurston 10/24/2008

Goodwill Mega Foods Donation Station Tacoma Goodwill EPR00290 Thurston 10/24/2008

Goodwill Olympia Store Tacoma Goodwill EPR00290 Thurston 10/24/2008

Goodwill South Lacey Donation Station Tacoma Goodwill EPR00290 Thurston 12/5/2008

Goodwill Thurston County Waste And Recovery Donati Tacoma Goodwill EPR00290 Thurston 10/24/2008

Goodwill Yelm WalMart Donation Station Tacoma Goodwill EPR00290 Thurston 4/14/2009



DateMIDWAY RECOVERY INC. MIDWAY RECOVERY INC. EPR00554 Thurston 1/26/2009

State Surplus Tumwater Site Dept of General Administration / Surplus EPR00480 Thurston 11/5/2008

Stanley’s Sanitary Service Stanley’s Sanitary Service LLC EPR00493 Wahkiakum 11/18/2009

CEP Recycle Walla Walla HHH EPR00471 Walla Walla 9/25/2008

Walla Walla Recycling Walla Walla Recycling Inc EPR00496 Walla Walla 11/21/2008

Goodwill Bellingham Store Seattle Goodwill EPR00310 Whatcom 9/18/2008

Recycling & Disposal Services, Inc.

Recycling & Disposal Services, Inc. EPR00510 Whatcom 12/3/2008

Safe And Easy Recycling Safe And Easy Recycling EPR00397 Whatcom 9/12/2008

Safe And Easy Recycling (North County) Safe And Easy Recycling EPR00397 Whatcom 1/13/2009

Salvation Army Bellingham The Salvation Army Seattle DHQ EPR00470 Whatcom 9/18/2018

Salvation Army Lynden The Salvation Army Seattle DHQ EPR00470 Whatcom 9/18/2008

Goodwill Pullman Donation Center Inland Northwest Goodwill EPR00334 Whitman 8/22/2008

Pullman Disposal Shop Pullman Disposal Service, Inc. EPR00299 Whitman 10/1/2008

Goodwill Chalet Plaza Donation Station Tacoma Goodwill EPR00290 Yakima 10/24/2008

Goodwill Selah Store Tacoma Goodwill EPR00290 Yakima 10/27/2008

Goodwill Yakima K Mart Donation Station Tacoma Goodwill EPR00290 Yakima 10/24/2008

Goodwill Yakima Red Robin Donation Station Tacoma Goodwill EPR00290 Yakima 10/27/2008

Goodwill Yakima Store Tacoma Goodwill EPR00290 Yakima 10/27/2008

Goodwill Zillah Food Center Donation Station Tacoma Goodwill EPR00290 Yakima 12/5/2008

Salvation Army Union Gap The Salvation Army Seattle DHQ EPR00470 Yakima 9/18/2008

Salvation Army Yakima The Salvation Army Seattle DHQ EPR00470 Yakima 9/18/2008

Sunnyside Christian Thrift Shop Sunnyside Christian Thrift Shop EPR00566 Yakima 3/6/2009

Union Gospel Mission Yakima Union Gospel Mission Yakima EPR00568 Yakima 2/27/2009

Yakima Waste Systems Granger Yakima Waste Systems, Inc. EPR00463 Yakima 11/5/2008

Yakima Waste Systems Yakima Yakima Waste Systems, Inc. EPR00463 Yakima 11/5/2008


Appendix 3 – Questions Asked of Stakeholders

Maximum of 10 - 15 Asked per Stakeholder

Question Stakeholder Categories for Question

1. Operations Questions

a. Are there aspects of the system are working particularly well and what, if anything, is not working well?

All

b. How has the program performed compared to your expectations prior to the program implementation?

All

Do you think the establishment of an Authority (Washington) and a default state contractor program (Oregon) helped start up? Are these default programs important to the operation of the overall system?

Regulators, Program Managers, Manufacturers, Local Officials, Processors/Recyclers, NGOs, Reuse Organizations

c. Why do you think Washington had only a single program in Year 1 while Oregon had 4 – and now only 1 in WA and 3 in OR? What drove the decisions made by manufacturers to pursue, or not to pursue, independent manufacturer plans?

Program Managers, Manufacturers

d. How have plans/programs managed the distinctions between covered entities that are eligible to receive free recycling, and non-covered entities? How is this working? And covered electronics vs. not?

Regulators, Program Managers, Participating Collectors, Local Officials

e. What were the noteworthy operational challenges that you faced during startup and implementation?

Regulators, Program Managers, Participating Collectors, Processors/Recyclers, Reuse Organizations, Transporters

f. How are the independent programs structured and who manages it?

Program Managers, Manufacturers

g. What do you like best about the independent program versus the state default program? Why did you choose which plan for 2009 and 2010?

Manufacturers

h. How is the system working regarding peripherals?Regulators, Program Managers, Participating Collectors, Local Officials, Processors/Recyclers

2. Economic questions

a. How has the qualified collector/fair compensation system under the Authority worked for collectors (Washington)? Do most collectors consider the compensation arrangement fair with respect to the level of services they provide? And for the Authority? How has it worked for the Authority that they have to use all qualified registered collectors?

(Washington only) Regulators, Program Managers, Participating Collectors, Non-Participating Collectors, Local Officials

b. How has the competitive collector services system worked in Oregon? Are most entities wanting to collect hired by an approved plan? Are their compensation amounts adequate? How has this worked from the Plans’ perspective?

(Oregon only) Regulators, Program Managers, Participating Collectors, Non-Participating Collectors, Local Officials

c. Is the compensation level you are receiving enough to cover your costs?

Participating Collectors, Non-Participating Collectors, Transporters



d. What notable economic impact has been observed during initial program implementation on non-collector stakeholders – covered entities, processors/recyclers, retailers and manufacturers. Key principals will be asked to provide observations about how changes brought about by the E-Cycle system have affected them economically, and any observations about their perception of the economic impact on other stakeholder classes and on service providers operating outside the program.

Regulators, Program Managers, Manufacturers, Local Officials, Processors/Recyclers, NGOs, Reuse Organizations

3. Environmental questions

a. What changes in flows have been observed? Specifically, changes in the frequency of covered electronics going into audited recycling channels that were formerly going into landfills and/or unaudited recycling channels. Are there winners and losers – and who are they? As there is little or no data on the amount of covered electronics currently and formerly landfilled and/or entering unaudited recycling channels these questions will seek anecdotal information in the form of observations from stakeholders that will be compiled and analyzed and reported on a qualified, not quantified basis.

Regulators, Program Managers, Participating Collectors, Non-Participating Collectors, Local Officials, Processors/Recyclers, NGOs, Reuse Organizations

b. What changes in product design are underway resulting from these programs? For recyclers - do you ever talk to the OEMs about design/recycling issues?

Manufacturers, Processors/Recyclers

c. For those participating in the program, how have they changed their practices? (could be both environmental and operational)

Participating Collectors, Processors/Recyclers, Reuse Organizations

d. For those not participating in the program, have they changed their practices? (could be both environmental and operational)

Participating Collectors, Processors/Recyclers, Reuse Organizations

e. Have the standards implemented by plans (preferred standards) impacted practices?

Program Managers, Manufacturers, Processors/Recyclers

f. Do you think that the E-Cycle program assures responsible management of the covered electronics? Do you have confidence that responsible management is happening?

All

g. In Washington, has the new reuse law made a difference in how they do business and how much is reused?

(Washington only) Participating Collectors, Non-Participating Collectors, Reuse Organizations

h. Has the approach to reuse in the Oregon program made a difference in how they do business and how much is reused? Ask both collectors and processors.

(Oregon only) Participating Collectors, Processors/Recyclers, Reuse Organizations

i. Do you think the vast majority of CEPs/CEDs with no reuse value are being handled in the system? How much leakage?

Program Managers, Manufacturers, Participating Collectors, Non-Participating Collectors, Local Officials, Processors/Recyclers, NGOs

4. Policy questions

a. Is the financing mechanism working? Are there possible improvements to that part of the system? Does the law specify too much or too little about how plans should be financed? What improvements could be made to the legislation to enable sustainable financing for Authority/Stewardship org?

Regulators, Program Managers, Manufacturers, NGOs



b. Are there lessons learned from the process for allocating responsibility across producers?

i. Washington – how is the separation of who allocates responsibility concerning overall manufacturer obligations in Washington (return share only) and the Authority financing policy (market share or return share, or any other equitable method) playing out through system implementation? How do stakeholders view this separation of responsibilities through the first 9 months of program implementation?

i. Oregon – how has the policy for television manufacturers in the State Contractor Program (i.e., financing responsibility based on market share of TV manufacturers participating in the SCP) worked through the first 9 months of program implementation?

Regulators, Program Managers, Manufacturers

b. Do you think the administrative costs of a statistically viable sampling program outweigh its utility in a producer responsibility system?

Regulators, Program Managers, Manufacturers, Processors/Recyclers

c. What challenges have been observed when obtaining and managing share data (both return share and market share data) that affect overall system fairness and/or performance?

Regulators, Program Managers

d. Does a single plan or multiple plans are preferable – (work better for some or all stakeholders)?

All

e. What are the challenges and benefits created where there are shared collectors across programs? What are the dynamics that are generated from this? Are the rules or guidelines specific enough to provide a robust collection system re: shared collectors and a level playing field? What data reporting system should be implemented to manage these situations? Are some types of collector sharing working in Oregon? Are some not?

Regulators, Program Managers, Manufacturers, Participating Collectors, Local Officials

f. How has the lack of a set performance target affected Washington? How has a set performance targets in Oregon played out?

Regulators, Program Managers, Manufacturers, Processors/Recyclers

g. What are the effects of other service requirements on the program such as a) providing at least one collection location in all cities with a population > 10,000 and b) in Washington requiring the WMMFA to accept all qualified collectors into the program?

Regulators, Program Managers, Manufacturers, Participating Collectors, Non-Participating Collectors, Local Officials, Processors/Recyclers

h. Do you view specific elements in the system as particularly fair or unfair? What are those elements, and why or why not?

All

i. Are there requirements that you would like changed because they are particularly challenging and/or not working? Around the approve Plans/Programs?

All

j. How about curbside collection – should and/or is this happening within the system currently?

Collectors

5. Overall lessons learned questions

a. What do you believe are the lessons learned to date?All

b. Are there lessons learned during the implementation that shed light on the feasibility/economic implications of adding new covered products and/or creating new producer responsibility systems?

All


Appendix 4 – Distribution of Stakeholders Interviewed

Government officials 9 (6 from Washington, 3 from Oregon)

Plan/program managers running recycling systems 5

Manufacturers 5

Collectors participating in the program 6

Potential collectors not participating in the program 2

Processors/recyclers

6(6 of the 10 processors/recyclers participated in the full interview. 9 of the 10 processors answered questions

specifically related to employment issues)

Refurbishment/reuse organizations 3

Environmental NGOs 1

Transporter 1

Total Number of Stakeholders Interviewed 38